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RENOIR v. C. I. R

No. 18237.

321 F.2d 605 (1963)

Jean RENOIR and Dido Freire Renoir, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

August 7, 1963.

Attorney(s) appearing for the Case

J. Everett Blum, Beverly Hills, Cal., for petitioners.

Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Benjamin M. Parker, and Philip B. Heymann, Attys., Tax Div., Dept. of Justice, Washington, D. C., for respondent.

Before CHAMBERS, HAMLEY and HAMLIN, Circuit Judges.

HAMLIN, Circuit Judge.

Jean and Dido Renoir filed a petition with this court to review a decision of the Tax Court (37 T.C. 1180) involving their income tax liability for the years 1956 and 1957.

The facts are not in dispute. Petitioners arrived in France on October 1, 1953, and remained continuously in Europe until July 15, 1956. While in Europe, Jean Renoir performed personal services as a motion picture director and writer...

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