Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined deficiencies in income tax in the amount of $1,098.61 for 1947 and $669 for 1948. The question for decision is whether petitioner's earnings derived from employment on Okinawa Island during 1947 and part of 1948 are to be excluded from his gross income pursuant to Section 116 (a) of the Internal Revenue Code.
Petitioner is a resident of College Park, Georgia. He filed...
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