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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
2003.
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