- 4 - information concerning his claim that his income was exempt from Federal income tax. In response, petitioner submitted a second 2002 Form 1040NR and attached a photocopied article regarding the treaty that exempts particular Belgian residents, who are temporarily in the United States, from U.S. income tax in certain circumstances. On this second Form 1040NR, petitioner listed his occupation in the United States as “Anesthesia trainee in training”. Petitioner filed a 2003 Form 1040NR in which he reported wages of $59,323 and miscellaneous income of $5,700 as “income exempt by a treaty”. He listed his occupation in the United States as “Anesthesia Trinee [sic]”. On February 22, 2006, respondent issued to petitioner a notice of deficiency for the 2002 and 2003 tax years in which he explained that “Maimonides Medical Center and Fairview Hospital are not universities or other ‘recognized educational institution(s).’ The income you received is not exempt from U.S. income tax under Article 20 of the income tax treaty between Belgium and the United States.” Respondent issued to petitioner a Form 4549, Supplement to the Notice of Deficiency (supplement), asserting adjustments that decreased petitioner’s deficiencies and section 6662(a) penalties from what was determined in the notice of deficiency. In the supplement, and pursuant to article 21 of the treaty, respondent asserted that the first $2,000 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007