Memorandum Findings of Fact and Opinion
This proceeding involves a deficiency in income tax of the petitioner for the taxable year 1946 in the amount of $7,118.79. Petitioner concedes a portion of the deficiency. The only controversy presented for our consideration is whether the petitioner, a nonresident alien, was engaged in trade or business within the United States at any time during the taxable year.
Findings of Fact
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