These proceedings involve deficiencies in petitioner's income tax for 1955, 1956, 1958, and 1959 in the respective amounts of $61,035.68, $90,825.54, $317,970.37, and $106,081.18. The petition alleges that respondent erred in determining such deficiencies in the income tax liability of petitioner who was a citizen of the United States, a resident of the Republic of the Philippines, and a member of a Philippine conjugal partnership during the taxable years in that no part...
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