Memorandum Findings of Fact and Opinion
The Commissioner determined an income tax deficiency of $3,928.74 for 1918; $3,286.94 for 1919; and $1,905.04 for 1920. Petitioner, a United States citizen resident in the Philippine Islands during the taxable years, contends (1) that he is not taxable under the Revenue Act of 1918, and that the Commissioner has no authority to determine, assess or collect an income tax from him; and, in the alternative, (2) that assessment...
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