ARUNDELL, Judge:
Respondent determined a deficiency in income tax for the calendar year 1954 in the amount of $49,074.75.
The only issue remaining to be decided is whether petitioner, a nonresident alien who had a "permanent establishment" in the United States until March 15, 1954, is taxable on $69,641.77 of royalties from sources within the United States received by him between March 15 and December 31, 1954, or whether such royalties are exempt from...
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