Park v. Commissioner
United States Tax Court
Held, petitioner, an alien, was a resident of the United States for Federal income tax purposes, within the meaning of the regulations under sec. 871, I.R.C. 1954, during each of the years 1972, 1973, 1974, and 1975.
1Opinion of the Court
Featherston, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax and an addition to the tax under section 66541 for each of the years 1972,1973, 1974, and 1975. The case is presently before the Court for the limited purpose of determining whether petitioner was a resident or nonresident alien during the years in question.2
FINDINGS OF FACT
Petitioner was born on March 16, 1935, in the City of Sinchang, County of Sunchun, which is now part of the Peoples Republic of Korea (North Korea). He is, and at all relevant times has been, a citizen of the Republic of Korea (South…
2Cases cited15 opinions
- Valley Finance, Inc. v. United StatesCourt of Appeals for the D.C. Circuit · 1980
- Swenson v. ThomasCourt of Appeals for the Fifth Circuit · 1947
- Commissioner of Internal Revenue v. NubarCourt of Appeals for the Fourth Circuit · 1950
- Adams v. CommissionerUnited States Tax Court · 1966
- Dillin v. CommissionerUnited States Tax Court · 1971
10 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Garzon v. United StatesDistrict Court, S.D. Florida · 1985
- Whyte v. CommissionerUnited States Tax Court · 1986
- Elghanian v. Comm'rUnited States Tax Court · 2005
- Bigio v. CommissionerUnited States Tax Court · 1991
- Crowley v. CommissionerUnited States Tax Court · 1993
4 more not listed; retrieve them via the Exa API.