- 21 - work full time and earn wages for 14 months. Id. at 557. His contacts with the economy were greater than those of petitioner. Petitioner obtained a real estate license in Florida, and he considered real estate syndication and viewed real estate while in Boston. However, he was not employed in the United States from 1969 to 1979, and he did not earn any income in the United States from real estate or any other business activity during those years. He did not show that he had economic ties to the United States similar to the taxpayer in Siddiqi. Petitioner traveled to London, Spain, France, and Israel in 1979. In that year his trips to and activities in the United States were very limited. He occupied an apartment in New York in December, but he did not show an intent to form ties to the community. During his time as a student, in Boston, and in New York in 1979, petitioner was not deeply or continuously involved in business, personal, social, or political affairs in the United States. Cf. Park v. Commissioner, 79 T.C. at 289. c. Petitioner’s Family Members It appears from our record that petitioner’s parents and brother, Phillip Elghanian, have been U.S. residents since 1978 or 1979. Petitioner contends that this shows that he was also a resident in 1979. We disagree. Petitioner has made other choices, apparently independent of his family.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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