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GOOSEN v. COMMISSIONER

Docket No. 23323-09.

136 T.C. 547 (2011)

RETIEF GOOSEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed June 9, 2011.

Attorney(s) appearing for the Case

Aaron H. Bulloff, Stephen L. Kadish, and Matthew F. Kadish, for petitioner.

Lindsey D. Stellwagen, Warren P. Simonsen, Nina E. Chowdhry, and Jeffrey E. Gold, for respondent.

KROUPA, Judge:

Respondent determined that petitioner, a non-domiciliary United Kingdom (U.K.) resident, had Federal income tax deficiencies from income he received from worldwide endorsement agreements for 2002 and 2003 (the years at issue).1 Respondent determined a $20,224 deficiency for 2002 and a $144,474 deficiency for 2003.

After concessions, there are three issues for decision...

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