Memorandum Opinion
TIETJENS, Judge:
Respondent determined a deficiency of $2,290.92 in petitioners' income tax for the year ending December 31, 1972.
The issues are:
(1) Whether the moving expense reimbursement petitoners received from Ford Motor Company is income from a source without the United States for purposes of calculating the overall limitation on foreign tax credit pursuant to section 904(a)(2), I.R.C. 1954.
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