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KRAVETZ v. COMMISSIONER

Docket No. 703-84.

50 T.C.M. 1122 (1985)

T.C. Memo. 1985-496

Sydney C. Kravetz v. Commissioner.

United States Tax Court.

Filed September 23, 1985.

Attorney(s) appearing for the Case

Stanley Schoenbaum, 1420 Alamo Nat'l. Bldg., San Antonio, Tex., for the petitioner. Patricia Y. Taylor and Marty J. Raisanen, for the respondent.

Memorandum Opinion

FEATHERSTON, Judge:

Respondent determined deficiencies in the amounts of $24,921 and $21,848 in petitioner's Federal income taxes for 1980 and 1981, respectively. After concessions, the only issue for decision is whether petitioner, a United States citizen married to a nonresident alien, is entitled to compute his personal service income under section 1348,1 even though he elected not to file joint returns...

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