Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency in income tax of the petitioner for the year 1953 in the amount of $6,428.78.
The sole issue for decision is the extent to which amounts constituting foreign source earned income within the meaning of section 116, Internal Revenue Code of 1939, received in taxable year 1953, but attributable to services performed during 1952, are excludable from gross income...
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