The Commissioner determined deficiencies in petitioner's income tax in the amounts of $127.80 and $2,020.38 for the calendar years 1967 and 1969, respectively. Petitioner was a United States citizen who, as a civilian employee of the United States Air Force, worked and resided in Spain; his wife was a citizen and resident of Spain. The sole remaining issue is whether one-half of petitioner's gross income belonged to his wife under Spanish community property law and was therefore...
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