United States Tax Court June 13, 2011, Docket Nos. 14159-09, 30063-09. (Sang J. Park v. Commissioner)

SANG J. PARK & WON KYUNG O, PETITIONERS v.

COMMISSIONER OF INTERNAL REVENUE,

RESPONDENT

SANG J. PARK, PETITIONER v. COMMISSIONER OF

INTERNAL REVENUE, RESPONDENT

Docket Nos. 14159–09, 30063–09. Filed June 13, 2011.

P, a South Korean national and nonresident alien, had U.S.

gambling winnings and interest income that was not effec-

tively connected with a U.S. trade or business.