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SOLANO v. COMMISSIONER

Docket No. 2728-71.

62 T.C. 562 (1974)

HELEN ROBINSON SOLANO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 31, 1974.

Attorney(s) appearing for the Case

Jules G. Körner III, for the petitioner.

Howard L. Williams, for the respondent.

OPINION

SIMPSON, Judge:

The respondent determined a deficiency of $514.17 in the Federal income tax of the petitioner for the year 1969. The issue for decision is whether the petitioner, a United States citizen and bona fide resident of Spain, may exclude the portion of the income which was earned by her husband, a nonresident alien, by the performance of personal services in Spain, and which was attributable to her by virtue of the community property...

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