OPINION
GOFFE, Judge:
Respondent determined deficiencies in the Federal income tax of petitioner for the taxable years 1965 and 1966 in the amounts of $1,604.10 and $4,834, respectively. On March 11, 1971, petitioner filed a motion for severance of issues wherein he requested severance of the issue of whether his filing of Form 1040C for the taxable year 1965 when departing from the United States constituted an income tax return so as to bar assessment...
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