SHERMAN v. COMMISSIONER

Docket No. 1335-63.

24 T.C.M. 650 (1965)

T.C. Memo. 1965-126

Frank J. Sherman and Madeline E. Sherman v. Commissioner.

United States Tax Court.

Filed May 11, 1965.


Attorney(s) appearing for the Case

Leonard Boreman Frick Bldg., Pittsburgh, Pa., for the petitioners. Hobart Richey, for the respondent.


Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined a deficiency in the income tax of petitioners for the taxable year 1960 in the amount of $905.65. Petitioners claim an overpayment of $2,157.10 in their petition, alleging that all amounts received from S. G. Yulke Company in 1960 are exempt from taxation.

The only issue for decision is whether the petitioner, Frank J. Sherman, was a bona fide resident of India for an uninterrupted...

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