Mehrdad Hamzeye Langroudi - Page 12

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               Petitioner filed his 2002 and 2003 income tax returns and              
          reported all of his income from wages.  At the time of filing,              
          petitioner was new to this country and unfamiliar with the U.S.             
          tax system, let alone the intricacies of the tax convention                 
          between the United States and Belgium.  Even respondent had                 
          difficulty applying the treaty to petitioner’s situation, as                
          evidenced by the necessity of issuing a supplement to his                   
          original notice of deficiency.  We hold that petitioner is not              
          liable for the accuracy-related penalties under section 6662.               
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          

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