Respondent determined a deficiency in petitioner's income taxes in the amount of $41,267.73 for the year 1946. In an amended answer, respondent asserted an increased deficiency for that year in the amount of $4,024.17. The issue is whether petitioner, a nonresident alien, was engaged in a trade or business within the United States during the year in controversy as a result of his security transactions through a resident agent so as to permit taxation of his income therefrom...
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