The taxpayer, who had moved with his wife to Florida in September 1992, had thereupon ceased to be a resident of Canada notwithstanding that he retained a number of minor ties with Canada including maintaining two bank accounts there for the purpose of processing pension payments, visits to Canadian family members and the holding of some Canadian assets on behalf of his son. Rip J. stated (at p. 2737) that "the fact that he reported only his United States income in his United States income tax return is a matter for the Internal Revenue Service and not for me or the Canadian Revenue Agency".
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