Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined an income tax deficiency against petitioners for the year 1961 in the amount of $2,654.93.
The principal issue in this case is whether the petitioners were resident or nonresident aliens of the United States in the year 1961. If they were residents of the United States, then three subsidiary questions must be resolved. They...
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