MADDEN, Judge.
The plaintiff is the administrator of the estate of Lewis B. Mallery, who died on December 30, 1945. He sues for a refund of income taxes paid by him on the income of the decedent for the year 1945.
The decedent had been an employee of the National City Bank of New York from June 4, 1929, until his death. Except for a period of one month before he was sent abroad, all of his services for the bank had been in foreign countries, of which he was...
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