Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioner's Federal income tax for the taxable year 1975 in the amount of $3,421.18. The sole issue for decision is whether, during 1975, petitioner was domiciled in California, a community property state, and thus was entitled to attribute one-half of his income to his nonresident alien spouse.
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