Mehrdad Hamzeye Langroudi - Page 4

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               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                  
               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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