Mehrdad Hamzeye Langroudi - Page 5

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          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                   
               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 of              

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