Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
In these consolidated proceedings the Commissioner determined deficiencies of $721 in the income tax of Amy L. Lockhart and of $831 in the income tax of Tex E. Lockhart for 1945.
The only issue is whether Tex E. Lockhart was a "bona fide resident" of Saudi Arabia during 1945 within the meaning of section 116 (a) (1) of the Internal Revenue Code.
Petitioners are husband and wife residing...
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