Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $380.57 in petitioner's Federal income tax for the year 1967. This was based on the ground that petitioner's wife, Patricia M. Tracy, was a nonresident alien of the United States in 1967 and, therefore, the petitioner was not entitled to file a joint Federal income tax return with his wife for that year.
In his original and amended petitions filed in this...
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