Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency of $1,573.55 in the income tax of James M. Wilson and Agnes E. Wilson for the calendar year 1966. The issues for decision are as follows:
(1) Whether the amount of $10,146.65 received by Mr. Wilson while employed in South Vietnam constitutes taxable income?
(2) If that amount is taxable, whether Mrs. Wilson is liable for the income tax imposed upon...
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