OPINION
WILBUR, Judge:
Respondent determined a deficiency of $2,850.26 in petitioner's Federal income tax for the calendar year 1973. The issues for decision are (1) whether petitioner is entitled to use a taxable year other than a calendar year, and (2) whether $12,806.28 of income earned by petitioner in the United States during 1973 is exempt from U.S. tax under the provisions of the income tax treaty between the United States and the United Kingdom...
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