Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined a deficiency in the joint Federal income tax return of the petitioners for the taxable year 1970 in the amount of $2,863.77. The issue for our decision is whether petitioner Abraham Barocas was a "bona fide resident" of Nassau, Bahamas, for a period which included an "entire taxable year" so that earnings attributable to services
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