NOLD v. COMMISSIONER

Docket No. 1466-66.

26 T.C.M. 802 (1967)

T.C. Memo. 1967-171

Ewell K. and Phyllis Nold v. Commissioner.

United States Tax Court.

Filed August 23, 1967.


Attorney(s) appearing for the Case

George A. Hrdlicka, for the petitioners. Ralph V. Bradbury, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

DAWSON, Judge:

Respondent determined an income tax deficiency against petitioners for the year 1964 in the amount of $4,029.07. Petitioners claim an overpayment of $1,922.23 for the same year.

The only issue for decision is whether petitioner Ewell K. Nold was a bona fide resident of a foreign country or countries for an uninterrupted period which included an entire taxable year, so that the income from his...

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