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Conrad Black is seen in this file photo.

Fred Lum/The Globe and Mail

Conrad Black is appealing a federal Tax Court judgment that deemed him to be a Canadian resident in 2002 and said he owed taxes for that year.

Black's lawyers have filed notice of appeal with the Federal Court of Appeal asking it to set aside the Jan. 14 judgment.

In the appeal notice, they say the Tax Court of Canada made an error in law when it found Black to be a resident of Canada in 2002 for the purpose of the Income Tax Act.

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His lawyers had argued that, under their interpretation of the Canada-United Kingdom Income Tax Convention, Black was, for tax purposes, a resident of the United Kingdom during that year.

They are also asking the appeal court to reconsider the amount the Canadian Revenue Agency claims Black owes taxes on. The government has estimated the amount of income and benefits Black owes taxes on may be as high as $5.1-million.

Black's lawyers have also asked that the appeal be heard in Toronto, where Black has been living in Toronto since 2012, when he finished serving 37 months in the U.S. for convictions on fraud and obstruction of justice relating to his time as the head of media giant Hollinger.

An appeal court tossed out two other fraud convictions against him and against two other Hollinger executives.

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