Memorandum Findings of Fact and Opinion
COHEN, Judge:
Certain of the facts in this case have been stipulated, and the stipulation and the exhibits attached thereto are incorporated herein by reference.
At the time he filed his petition in this case, petitioner resided in Greenwich, Connecticut. He filed his income tax return for the taxable year 1977 with the Internal Revenue Service Center, Andover, Massachusetts. In...
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