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DE LA BEGASSIERE v. COMMISSIONER

Docket No. 60857.

31 T.C. 1031 (1959)

JOYCE DE LA BEGASSIERE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 25, 1959.

Attorney(s) appearing for the Case

Sidney Gelfand, for the petitioner.

Charles B. Markham, Esq., for the respondent.

The Commissioner determined a deficiency of $17,967.02 in income tax of the petitioner for 1951. The only issue for decision is whether the Commissioner erred in holding that the petitioner was "not entitled to file a joint return with your husband, Jacques de la Begassiere, for the year 1951, in accordance with Section 51 (b) (2) of the Internal Revenue Code of 1939, for the reason that he was a non-resident alien during part of such taxable year."

FINDINGS OF FACT...

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