The memorandum calculates the total number of days JEE has been present in the U.S. as of December 15, 2010, according to IRC Reg. 937-1. It details the days spent in the U.S. during specific periods and concludes that JEE would have a total of 85 days in the U.S. if he remains for the rest of the year, which is less than the permitted 90 days.
documents/EFTA01155770.pdf
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