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PARK v. COMMISSIONER

Docket No. 3410-77.

79 T.C. 252 (1982)

TONGSUN PARK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 10, 1982.

Attorney(s) appearing for the Case

Sheldon S. Cohen, Henry G. Zapruder, Bradley S. Waterman, and Jeffrey Kurzweil, for the petitioner.

Stephen M. Miller and Christina M. Burkholder, for the respondent.

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...

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