Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
The Commissioner has determined a deficiency in the petitioner's income tax in the amount of $1,960.38 for the calendar year 1954. The sole issue for determination is whether the petitioner is entitled to a partial exemption for the seaman's wages he earned while serving aboard an American ship operating between ports in Japan and Korea, under section 911(a)(2) of the Internal Revenue Code of 1954...
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