The U.S. Tax Court has found that South Korean businessman Tongsun Park was a resident of the United States from 1972 through 1975, which makes his substantial earnings subject to U.S. income tax.

The ruling, released yesterday, is the first in a two-step process. Another trial must be held on the amount of tax owed.

According to Sheldon S. Cohen, a former commissioner of internal revenue who is Park's attorney, the Internal Revenue Service originally asserted that Park owed $3.9 million in taxes. The government is holding "a lot of his assets" for possible use in a settlement, Cohen said.

Cohen said he has not decided whether to appeal this initial finding, but "more than likely we'll go through the second" trial before deciding whether to appeal.

"In our opinion," the tax court said, Park's "United States homes, investments, business activities and political, social and other ties were so deep and extensive as to show his stay in this country throughout 1972, 1973, 1974 and 1975 was of such an extended nature as to constitute him a resident."

Park was the central figure in the so-called "Koreagate" affair of the late 1970s, although he was not convicted. He had many friends in Congress and was active in the Washington social scene. During each of the four years in question Park spent 180, 199, 198 and 161 days in the United States, according to the court, substantially more than he did in South Korea.