OPINION
FORRESTER, Judge:
Respondent has determined a deficiency of $799.49 in petitioners' income tax for the calendar year 1966. The issues for our decision are the following: (1) Whether petitioners are precluded by collateral estoppel from arguing that it is unconstitutional to deny them an exemption under section 911(a)(2), I.R.C. 1954, for the wife's "community share" of salary paid her husband by the U.S. Government, because such share is not...
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