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RENOIR v. COMMISSIONER

Docket No. 87205.

37 T.C. 1180 (1962)

JEAN RENOIR AND DIDO FREIRE RENOIR, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 30, 1962.

Attorney(s) appearing for the Case

J. Everett Blum, Esq., for the petitioners.

Douglas W. Argue, Esq., for the respondent.

OPINION.

BRUCE, Judge:

The respondent determined deficiencies for the calendar years 1956 and 1957 in the respective amounts of $9,318.37 and $2,441.19. The sole issue for decision is the extent to which amounts received in the taxable years for personal services performed in France are excludible from taxable income. All the facts are stipulated and are found accordingly.

The petitioners, husband and wife, were residents and domiciled in...

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