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The term “residence” and “domicile” are not synonymous;
however, to be a resident, the taxpayer must have some degree of
permanent attachment to the country of residence. Park v.
Commissioner, 79 T.C. 252, 287 (1982), affd. without published
opinion 755 F.2d 181 (D.C. Cir. 1985). An individual may be a
resident of the United States without terminating his or her
residence in another country. Id. at 287-288.
2. Whether Petitioner Was a Resident of the United States
in 1979
Petitioner argues that the following establish that he was a
U.S. resident from 1969 through the years at issue: (a) He was
issued a green card in 1965; (b) he was in the United States from
1969 through 1977 and part of 1979; (c) his parents, brother, and
some other family members lived here; and (d) he told some
members of his family and friends that he wanted to live in the
United States.
a. Petitioner’s Green Card
Petitioner argues that the fact that he received a green
card and permanent lawful resident status in 1965 shows that he
was a resident of the United States from 1969 through the years
in issue. We disagree. Issuance of a green card in 1965, when
petitioner was about 14 years old, has little or no bearing on
whether petitioner was a resident in 1979. For that we look to
events which occurred closer to 1979.
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