OPINION.
HARRON, Judge:
The Commissioner determined a deficiency in income tax for the calendar year 1952 in the amount of $1,097.64. The deficiency, for the most part, results from the Commissioner's determination that the rates of tax provided by sections 11 and 12 of the 1939 Code are applicable in determining the correct United States income tax due from petitioner.
The petitioner, a citizen of the United States, was a resident of Canada...
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