This proceeding involves deficiencies in income tax of petitioners for the years 1951 and 1952 in the respective amounts of $132.80 and $90.34. Petitioners filed timely claims for refund in the amount of $782.66 for the year 1951, and $917.96 for 1952.
The primary issue is whether petitioners are immune from Federal income tax on the amounts received for services rendered in the taxable years involved under contracts of employment with the Government of American Samoa...
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