The respondent determined a deficiency in income tax of the petitioner for the taxable year 1946 in the amount of $650.92. Except for a minor question concerning an alleged payment on account of the deficiency, the sole issue for our decision is whether, under section 116 (a) (2), Internal Revenue Code, as in effect during 1946, the petitioner was a bona fide resident of a foreign country or countries for a period of at least 2 years before the date on which he changed his...
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