Memorandum Findings of Fact and Opinion
The respondent has determined that deficiencies exist in petitioner's income taxes for the years 1947 and 1948 in amounts of $1,094.40 and $1,085.74, respectively.
The petitioner excluded the entire income earned by him in those years claiming that under section 116 (a) of the Internal Revenue Code he was a bona fide resident of Afghanistan. The single question to be determined is factual, i. e., whether petitioner...
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