Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined a deficiency of $160 in petitioners' income tax for the year 1975. The issue for our decision is whether the requirements contained in sec. 152(b)(3)
Findings of Fact
At the time the petition herein was filed, petitioners resided in El Dorado, Arkansas.
During the year 1975, petitioners were resident aliens...
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