Respondent has determined deficiencies in petitioner's liability for withholding income tax at the source under section 143 (b) of the Internal Revenue Code for the calendar years 1941 and 1942, in the respective amounts of $192.50 and $281.25, a total of $473.75. The deficiencies result from respondent's inclusion, in computing the withholding tax liability, of sums of $200 and $800 payable in each year to two citizens and residents of France out of the net income of a testamentary...
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