Memorandum Opinion
VAN FOSSAN, Judge:
The respondent determined deficiencies in income tax for the years 1948 and 1949 in the respective amounts of $128.31 and $686.13.
Petitioner claims he was a bona fide resident of the Philippine Islands during the taxable years and is exempt from tax under the provisions of section 116 (a) (1)
The respondent held petitioner taxable and thus the issue was raised.
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