Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined deficiencies in petitioners' Federal income tax liabilities for 1981 and 1982 in the amounts of $4,161 and $17,554, respectively. Some issues have been settled, and the sole remaining issue for decision is whether in 1982 petitioner John T. Lemay established a tax home and a bona fide residency in Tunisia for the purposes of the section 911
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