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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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