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United States temporarily, that he had a foreign residence that
he had no intention of abandoning, and that he did not enter to,
for example, work or study. See supra p. 9 note 9, p. 19 note
13.
Fourth, petitioner’s statement in his application for
permanent residence in the United States in 1983 that he
“eventually” would like to permanently reside in the United
States seems at odds with the proposition that he already was a
U.S. resident.
b. Petitioner’s Years in the United States
Petitioner argues that the fact that he was in the United
States from 1969 through 1977 and part of 1979 establishes that
he was a U.S. resident in 1979. We disagree. Petitioner did not
work in the United States, participate in the economy or society,
or demonstrate a degree of permanent attachment to the United
States. Park v. Commissioner, 79 T.C. at 287; see Demore v. Kim,
538 U.S. 510, 544 (2003); In re Griffiths, 413 U.S. 717, 722
(1973); Sochurek v. Commissioner, 300 F.2d 34, 38 (7th Cir.
1962), revg. and remanding 36 T.C. 131 (1961).
Petitioners point out that we have held that a taxpayer who
entered the United States under a student visa was a U.S.
resident. Siddiqi v. Commissioner, 70 T.C. 553 (1978).
Petitioners contend that this case is like Siddiqi. We disagree.
The taxpayer in that case interrupted his formal education to
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