OPINION
DAWSON, Judge:
Charles A. Peterson and Georgia R. Peterson, husband and wife, filed a joint Federal income tax return for the year 1959 with the district director of internal revenue, Baltimore, Md., at a time when they lived in Hong Kong. Charles A. Peterson died on March 29, 1964, in Hong Kong. Georgia R. Peterson is the sole beneficiary of his estate. She now resides in Corpus Christi, Tex.
On June 18, 1965, the Commissioner mailed...
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