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PATINO v. COMMISSIONER

Docket No. 16826.

13 T.C. 816 (1949)

CRISTINA DEBOURBON PATINO, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 29, 1949.

Attorney(s) appearing for the Case

Aloysius F. Schaeffner, Esq., and J. Harlin O'Connell, Esq., for the petitioner.

William F. Evans, Esq., for the respondent.

This proceeding involves deficiencies in income tax for the years 1944 and 1945 in the amounts of $3,479.97 and $12,972.57, respectively, and a penalty for 1944 in the amount of $869.99. The primary issue is whether or not petitioner was a resident alien during the taxable years. Other questions relating to dividends, interest, capital gain, and the penalty asserted for failure to file a timely return depend, in part, upon the answer...

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