Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in income tax of $1,197.96 for 1943 and $329 for 1944 against James, and $329 for 1944 against Mary. The only issue is whether compensation which James received in 1943 and 1944 for personal services performed in Ireland is to be excluded from his taxable income under section 116(a).
Findings of Fact
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