Memorandum Findings of Fact and Opinion
KERN, Judge:
Respondent has determined a deficiency in petitioner's income tax for the year 1941 in the sum of $3,684.71. The two issues presented are (1) whether petitioner is a non-resident alien, and (2) whether certain lump sum payments received by petition, who is an author, from American motion picture companies for certain world rights in and to literary production of petitioner, constituted income from sources...
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