Mehrdad Hamzeye Langroudi - Page 3

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          be entered is not reviewable by any other court, and this opinion           
          shall not be treated as precedent for any other case.                       
               Respondent determined deficiencies in petitioner’s Federal             
          income taxes and accuracy-related penalties under section 6662(a)           
          as follows:2                                                                
                                             Accuracy-related Penalty                 
                Year           Deficiency         Sec. 6662(a)                        
               2002           $7,165                   $1,433.00                      
               2003           11,846                   2,369.20                       
               After concessions,3 the issues we must decide are:  Whether            
          petitioner’s wage income from residencies in anesthesiology in              
          2002 and 2003 was exempt from Federal income tax pursuant to the            
          tax convention between the United States and Belgium (the treaty)           
          and whether petitioner is liable for accuracy-related penalties             
          under section 6662(a).                                                      

               2 Respondent subsequently issued a Form 4549, Supplement to            
          the Notice of Deficiency (supplement), which reflects a reduction           
          in the determined 2002 and 2003 to $6,625 and $9,071,                       
          respectively.  As a result of the reduced deficiency                        
          determinations, the supplement reduces the determined 2002 and              
          2003 penalties to $1,325 and $1,814.20, respectively.                       
               3 The parties stipulated that petitioner received unreported           
          dividend and interest income in 2002 and 2003.  Anesthesiology              
          Associates of Boro Park, L.L.P., paid petitioner $5,700 in                  
          miscellaneous income during 2003.  As a result, respondent                  
          determined that petitioner was liable for self-employment tax.              
          Petitioner did not dispute respondent’s determination that he was           
          liable for self-employment tax on nonemployee compensation in               

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