Memorandum Opinion
ARUNDELL, Judge:
This proceeding was instituted to test the correctness of respondent's determination of deficiencies for the years 1937 and 1938 in the respective amounts of $3,987.46 and $2,432.31. The primary questions are the taxability of a citizen of the United States domiciled in the Philippine Islands on income having its source in that possession and, further, whether the income may be returned on a community property basis.<...
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