Memorandum Opinion
WILBUR, Judge:
Respondent determined a deficiency of $937.50 in petitioner's Federal income tax for the taxable year ended December 31, 1970. In addition to contesting the deficiency, petitioner claims an over-payment of $1,232.72.
The issue is whether or not petitioner, a nonresident alien, was engaged in a trade or business in the United States in 1970, and thus entitled to use the graduated rate schedule in computing her tax...
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