Gerald Topsnik is now 0 for 2 in the Tax Court (there are other cases outside the Tax Court as well) in his battle with the IRS regarding whether he owes various taxes, though both cases resulted in published opinion—so arguably he’s an important loser.  After an earlier loss in his 2014 case (Topsnik v. Commissioner, 143 TC No. 12, referred to as Topsnik IV in the current opinion) that dealt with failure to properly give up his permanent resident status for federal tax purposes, he was subject to U.S. tax as a resident until 2010.

In the current case (Topsnik v. Commissioner, 146 TC No. 1) the question arose regarding whether he owed tax in 2010 on an installment sale of stock in a U.S. corporation.   He entered into the agreement in 2004 and was to receive payments through 2013.