Until November of 1968, petitioner was a citizen and resident of the Federal Republic of Germany. During November, 1968, she was admitted to the United States as an immigrant and took up residency in New York. Petitioner was a limited partner in a partnership organized and doing business in the Federal Republic of Germany. The partnership's fiscal year ended December 31, 1968, and on that date petitioner's distributive share of the partnership income for the calendar year...
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