OPINION.
ARUNDELL, Judge:
Respondent determined a deficiency in income tax for the calendar year 1954 in the amount of $12,041.85. The parties have stipulated that:
If the Court determines that the petitioner was present within the United States for a period or periods aggregating 90 days or more during the calendar year 1954, then it is agreed by and between petitioner and respondent that the correct deficiency in this case is $11,054.22...
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