Petitioner Oakley S. Evans was an executive employee of the J. C. Penney Company from 1935 until his resignation on May 16, 1972. He held various executive positions for that company and worked in different locations until 1953 when he was assigned to the New York City office and took up residence in Darien, Connecticut. His residency in Connecticut continued until he resigned. Petitioners agree that the income they received from January 1, 1972 to January 14, 1972 (a period...
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