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TICE v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 24983-15.

160 T.C. No. 8

DAVID W. TICE, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed April 10, 2023.

Attorney(s) appearing for the Case

Joseph M. Erwin , for petitioner.

Matthew R. Delgado and Jeffrey D. Heiderscheit , for respondent.

PINION

In this case we again consider the timeliness of a notice of deficiency issued to a U.S. citizen who claimed to be a resident of the U.S. Virgin Islands (USVI) for 2002 and 2003 (years in issue). Taxpayers like petitioner—those who claimed bona fide residency in the USVI and filed returns only with the Virgin...

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