JELLINEK v. COMMISSIONER

Docket No. 71101.

36 T.C. 826 (1961)

RUDOLF JELLINEK AND MELITTA JELLINEK, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 11, 1961.


Attorney(s) appearing for the Case

David G. Sacks, Esq., for the petitioners.

Paul D. Barker, Esq., for the respondent.


DRENNEN, Judge:

Respondent determined deficiencies in income tax against petitioners for the taxable years 1952, 1953, 1954, and 1955 in the respective amounts of $4,458.69, $4,155, $4,225.17, and $3,550.12.

The sole issue is whether petitioner Rudolf Jellinek (hereinafter referred to as Rudolf) was a nonresident alien during the period 1952 through 1955.

The evidence consisted of a stipulation of facts with exhibits attached and the depositions...

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