OPINION
SIMPSON, Judge:
The respondent determined a deficiency of $514.17 in the Federal income tax of the petitioner for the year 1969. The issue for decision is whether the petitioner, a United States citizen and bona fide resident of Spain, may exclude the portion of the income which was earned by her husband, a nonresident alien, by the performance of personal services in Spain, and which was attributable to her by virtue of the community property...
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