Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined a deficiency in the petitioner's Federal income tax for 1971 of $1,752.88, and the petitioner claimed an overpayment in such tax of $841.00. Due to concessions, the only issue for decision is whether in 1971, the petitioner was domiciled in the State of Arizona, a community property State, so that one-half of his income could be attributed to his nonresident alien wife and...
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