Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined a deficiency in the income tax of petitioners for the taxable year 1958 in the amount of $1,863.08. The sole issue to be decided is whether respondent has erred in including in the gross income of petitioners $12,104.17 received by them as salary during their employment for a period including one full year on the island of Trinidad, West Indies.
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