Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in income tax of petitioner for the calendar year 1950 in the amount of $1,390.57. The primary question is whether petitioner was a bona fide resident of a foreign country or countries during the taxable year. In his petition, petitioner also questions the constitutionality of section 1622 and related sections of the Internal Revenue Code of 1939 relating to the withholding of income tax...
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