FORRESTER, Judge:
Respondent determined deficiencies in income tax and additions thereto as follows:
Year Deficiency Sec. 6653(a) 1964 --------------------------- $34,985.52 $1,749.28
The issues to be decided herein are: (1) Whether petitioner's long-term capital gains from the sale of stock are exempt from income tax under article VIII of the Income Tax Convention and Protocol...
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