Memorandum Opinion
RAUM, Judge:
The Commissioner determined a deficiency in petitioner's 1975 Federal income tax in the amount of $12,038.18. After concessions, the sole issue for decision is whether certain expenses paid by a United States citizen in operating a Mexican farming business were properly disallowed as a deduction because they were allocable to or chargeable against earned income excluded from gross income under section 911, I.R.C. 1954. The...
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