Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $1,342.91 in the income tax of the petitioner for 1945. The only issue for decision is whether the petitioner was a bona fide resident of a foreign country or countries during the entire taxable year 1945 so that amounts received for his personal services are to be excluded from gross income under section 116(a).
Findings of Fact
The petitioner, a citizen of the...
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