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BERTIN v. COMMISSIONER

Docket No. 107982.

1 T.C. 355 (1942)

MICHEL J. A. BERTIN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 29, 1942.

Attorney(s) appearing for the Case

Nathan Heims, C. P. A., for the petitioner.

F. S. Gettle, Esq., for the respondent.

Raymond F. Garrity, Esq., filed a brief as amicus curiae.

OPINION.

DISNEY, Judge:

This proceeding involves income taxes for the year 1939. The Commissioner determined a deficiency of $1,886.46, all of which is in dispute. The issue presented is as to the proper method of computation of the more than six months' period of bona fide nonresidence of a citizen of the United States, within the purview of section 116 (a) of the Internal Revenue Code.1 All of the facts were stipulated...

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