Faramarz and Mitra Elghanian - Page 21

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          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.                              








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