The Commissioner has determined deficiencies in petitioner's income tax for the years 1952 and 1953 in the respective amounts of $2,594.40 and $1,038.30. The deficiency for each of the taxable years is due to the determination by the Commissioner as stated in his deficiency notice:
The salaries paid to United States citizens for work performed in American Samoa are not exempt from taxation under the provisions of section 251 of the Internal Revenue Code.
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