Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $2,362.65 in petitioner's income tax for the year 1947. The only issue here presented is whether petitioner qualifies under section 116 (a) (1) so as to exclude from gross income the salary earned by him in the taxable year for personal services rendered in a foreign country.
Findings of Fact
Most of the following facts were stipulated:
Petitioner is an individual...
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