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Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated by this reference. When the petition was filed,
petitioner resided in Newport News, Virginia.4 Petitioner is a
citizen of the Kingdom of Belgium (Belgium); however, he has
resided in the United States from June of 2001 through the
present.
On July 1, 2001, petitioner began a 1-year residency in
internal medicine at Fairview Hospital, a Cleveland Clinic
hospital, and he completed it on June 30, 2002. Fairview
Hospital paid petitioner wages of $19,995.90 in 2002.
Petitioner began a residency in anesthesiology at Maimonides
Medical Center on July 1, 2002, and he completed it on June 30,
2005. Maimonides Medical Center paid petitioner wages of
$23,726.77 in 2002 and $49,033.12 in 2003. In addition,
University Group Medical Associates paid petitioner wages of
$10,290 in 2003.
Petitioner filed a 2002 Form 1040NR, U.S. Nonresident Alien
Income Tax Return, in which he reported wages of $43,721 as
“income exempt by a treaty”. On his return, petitioner listed
his occupation in the United States as “Anesthesia Trainee”.
Respondent subsequently requested that petitioner provide
4 Petitioner resided in New Jersey at the time of trial.
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Last modified: November 10, 2007