Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined a deficiency in petitioners' 1982 Federal income tax in the amount of $10,879. The issue for decision is whether petitioner Robert C. Bujol (hereinafter referred to as Bujol or petitioner) established a tax home in, and became a bona fide resident of, the United Arab Emirates (U.A.E.) for purposes of the section 911
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