HARRON, Judge:
The respondent determined a deficiency in income tax for the taxable year 1955 in the amount of $22,895.57. The main question is whether petitioner had a "permanent establishment" in the United States until March 19, 1955, within the meaning of the income tax convention between the United States and France and respondent's regulations adopted thereunder, with the consequence that author's royalties from U.S. sources received while he was in France...
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