$1.$ Anh Nguyen, a single $24-$year old, recently completed her undergraduate degree in accounting at Vietnamese National University in Hanoi. She applied to and was accepted into Southern California University, located in Burbank, California, to pursue a master$$s degree in taxation. She received her F$-1$ student visa and arrived at Los Angeles International Airport in the summer of $2023$ and started her courses almost immediately. She was extremely excited because this was her first trip to the United States. Although Anh was an exceptionally bright student, she was thoroughly enjoying the southern California lifestyle and took only enough courses to maintain her full$-$time student classification. As a result, it was going to take Anh a little longer to complete her master$$s degree in tax. Although Anh missed her family and friends back in Vietnam, international travel was very expensive, and so she returned home only on limited occasions. Her international travel schedule was as follows:

Arrival in the United States Departure from the United States

$8/12/202312/25/2023$

$1/6/20245/12/2024$

$6/10/202412/26/2024$

$1/4/2025$

Anh remained in the United States from January $4,2025$ through the end of $2026.$ During $2026,$ Anh managed to get an on$-$campus job that paid her $$6,000$ as compensation for working as a graduate assistant assisting SCU Professor Ira Ess with his research and grading.

Anh noticed that she had income tax and FICA taxes withheld from her paycheck. When she received her Form W$-2$ statement in early $2027,$ she realized that she needed to file a U$.$S$.$ tax return to get back her withholding.

Prepare a memo that addresses three issues: $(1)$ How is Anh going to be treated for U$.$S$.$ tax residency purposes? $(2)$ Is Anh$$s income from her student job taxable in the United States? $(3)$ Is Anh subject to FICA taxes? Be sure and support your memo with primary sources.

$2.$ As mentioned previously, Anh really enjoyed the lifestyle in southern California. After living in student housing her first year, she immediately moved off campus into a nearby apartment. Over time, Anh started to grow quite comfortable in the United States. Her English improved a great deal, she managed to get a California driver$$s license, and she even bought a used car that she registered in California so she could drive back and forth to school $($and perhaps occasionally to the beach$).$ She became very good friends with a number of her classmates and from time to time even dated one or two. At the end of $2026,$ she had been dating one student for approximately four months; the relationship was showing signs of becoming serious, but it was still too early to tell. Although Anh missed her friends and family back in Vietnam terribly, she was beginning to think maybe she could stay in the United States after she finished her degree, but only if she could find a firm to sponsor her work visa. Prepare an addendum to the previous memo that discusses the California residency treatment of Anh in $2026$ and determine whether her income is taxable in California.

$3.$ As a result of the income, she generated from her on$-$campus job, Anh found herself with a small amount of disposable income. In early $2026,$ she took $$1,000$ of her disposable income and purchased shares in Jefferson Realty Trust, a real estate investment trust $($REIT$)$ for which shares are traded on a major U$.$S$.$ stock exchange. In late $2026,$ she realized she needed to purchase some holiday presents for her friends, including her previously mentioned significant other, and sold all her shares in the REIT for a gain of almost $$800.$ She sold the REIT prior to the trust paying any dividends. What is the U$.$S$.$ treatment of Anh$$s gain on the sale of the REIT shares?