Memorandum Opinion
STERNHAGEN, Judge:
The Commissioner determined a deficiency of $3,418.33 in petitioner's 1939 income tax, denying that the petitioner was a nonresident for more than six months, which would entitle petitioner to the exclusion from gross income of the pro rata portion of his income allocable to the period of nonresidence. The facts are all stipulated. Other adjustments are not contested....
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