United States Tax Court.
Memorandum Findings of Fact and Opinion
TURNER, Judge:
Respondent determined income tax deficiencies against petitioner as follows:
Year Deficiency 1961.................. $339.19 1962.................. 302.77
The sole issue for decision is whether petitioner is taxable as a nonresident alien of the United States for the taxable years 1961 and 1962 under section 871(a) of the Internal Revenue Code...
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