Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $4,999.46 in petitioner's 1974 Federal income tax. The sole issue presented is whether petitioner was domiciled in Washington, a community property state, during 1974 so that one-half of his earnings would be attributable to his nonresident alien spouse and thus excluded from his gross income.
Findings of Fact
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