This case involves income taxes for the calendar years 1946 and 1947. Deficiencies were determined in the respective amounts of $1,076.89 and $1,199.36. The only question involved is whether the petitioner, a citizen of the United States, was a bona fide resident of a foreign country or countries during the 2 years, so that his income from sources without the United States was exempt from taxation under section 116 (a) (1) and (2) of the Internal Revenue Code.
FINDINGS...
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