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under section 6662(a) for 1989 for substantial understatement of
tax. We hold that he is not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners were married and resided in France when they
filed their petition.4
1. Petitioner’s Family and Early Years
Petitioner was born in Iran in 1950 or 1951. Petitioner’s
father and several of his father’s brothers owned businesses in
Iran which had 5,000-8,000 employees in the 1970s.
Petitioner’s father was born in Iran. His mother was born
in London. Petitioner attended school in Iran from 1957 to May
1965. Petitioner never worked for his family’s businesses in
Iran.
Petitioner applied for an alien registration receipt card
(green card)5 in 1965 when he was about 14 years old. In his
4 Petitioner testified that he and his wife resided in
France beginning before Sept. 11, 2001, and continuing through
the date of trial. Petitioners stated in the petition that their
mailing address was c/o Steven E. Golden, C.P.A., in New York,
New York. There is no evidence that they resided in New York
when they filed the petition.
5 "Green card" is the common name for a Form I-151, Alien
Registration Receipt Card. See Moorhead v. United States, 774
F.2d 936, 938-939 n.4 (9th Cir. 1985); Gooch v. Clark, 433 F.2d
74, 76 (9th Cir. 1970); see also sec. 264 of the Immigration and
Nationality Act (1952), ch. 477, 66 Stat 163, 224, as amended, 8
U.S.C. sec. 1304 (1994); 8 C.F.R. sec. 264.5 (2000); Gordon &
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