DRENNEN, Judge:
Respondent has determined deficiencies in income tax due from petitioner for the taxable years 1956 and 1957 in the respective amounts of $791.48 and $787.16.
The only issue for decision is whether petitioner, a United States citizen residing in Germany and not domiciled in a community property State during the taxable years, may treat, for Federal income tax purposes, one-half of his income as belonging to his wife, a nonresident alien...
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