Respondent has determined deficiencies in income tax for the calendar year 1943 against the petitioner in each of these proceedings in the sum of $564.80. The proceedings were consolidated for hearing and decision. The issue presented is whether or not income earned by petitioner Dudley A. Chapin for services performed for an American contractor at an Army base in Ireland is exempt from tax under section 116 of the Internal Revenue Code.
FINDINGS OF FACT.
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