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Respondent determined a deficiency of $1,354 in petitioner’s
1999 Federal income tax, and an addition to tax of $135 under
section 6651(a)(1).
The issues for decision are: (1) Whether petitioner, a
nonresident alien, is entitled to claimed Schedule A deductions,
and (2) whether petitioner is liable for an addition to tax under
section 6651(a)(1).
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in North Bergen, New Jersey, at the
time he filed his petition.
Section 7491(a) does not apply because petitioner did not
satisfy the requirements of that section. The burden of proof
remains on petitioner. Rule 142(a).
During 1999, petitioner, a British citizen, was a
nonresident alien in the United States. Petitioner owned rental
real property (rental property) in Union City, New Jersey.
Petitioner was a tenant stockholder of a cooperative housing
corporation (co-op) in North Bergen, New Jersey, where he resided
in 1999 while in this country.
Respondent received petitioner’s 1999 Form 1040NR, U.S.
Nonresident Alien Income Tax Return, on June 12, 2001. On his
Form 1040NR, petitioner reported net income of $13,729 from his
rental property (rental income) and $501 from taxable interest.
He showed a “zero” tax due on his Form 1040NR.
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