Memorandum Opinion
SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioner's Federal income taxes in the amounts of $3,507.60 for 1970 and $3,889.45 for 1971. The sole issue for decision is whether in 1970 and 1971, the petitioner was domiciled in a community property jurisdiction, so that one-half of his earnings could be attributed to his nonresident alien wife and excluded from his gross income.
All of the facts have been stipulated...
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