This proceeding involves a deficiency in income tax for the year 1947 in the amount of $483. Two questions are raised: Whether a deficiency may be claimed for a year for which the respondent has previously refunded taxes paid principally by withholding; and whether the petitioner was a bona fide resident of a foreign country in 1947 and thus exempt from income taxes under section 116 (a) of the Internal Revenue Code of 1939.
FINDINGS OF FACT.
The petitioner...
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