Before finding that the appeal of the taxpayer, who was enrolled in a Ph.D. program at a college of business administration in California (Touro University International), should be dismissed because the appeal was from a nil assessment, Bowman A.C.J. went on to state in obiter (at p. 3271):
I think it is strongly arguable that full-time attendance at a foreign university can include full-time attendance through the internet or on-line as is the case here. That view conforms to common sense and to the reality of modern technology.