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SCHONEBERGER v. COMMISSIONER

Docket No. 11885-78.

74 T.C. 1016 (1980)

BERT J. SCHONEBERGER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 7, 1980.

Attorney(s) appearing for the Case

Richard L. Carico, for the petitioner.

Alan C. Parsons, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency of $8,533.50 in petitioner's 1975 Federal income tax. The issue for decision is whether petitioner was a bona fide resident of France, entitled to the earned income exclusion of section 911(a)(1),1 during all or any part of the taxable year in question.2

FINDINGS OF FACT

Some of the facts...

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