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1. [1285] PROBLEMS Review the facts involving your client, Wolfgang, the German citizen in Problem...

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Accounting

1. [1285] PROBLEMS Review the facts involving your client, Wolfgang, the German citizen in Problem 2 at 1190. If Wolfgang is treated as a U.S. resident for year 3 under Section 7701(b) and is also treated as a resident of Germany for German tax purposes, is any relief available under the United States-Germany income tax treaty, assuming that it contains a provision identical to Article 4 of the U.S. Model Treaty in the Appendix? Applying Article 4 of that treaty, is Wolfgang a resident of the United States or Germany under the treaty

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