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SMITH v. COMMISSIONER

Docket No. 23371-82.

83 T.C. 702 (1984)

GEORGE E. SMITH AND THEODORA SMITH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 23, 1984.

Attorney(s) appearing for the Case

Andrew C. Barnard, for the petitioners.

Donald Rightnour, for the respondent.

OPINION

SCOTT, Judge:

Respondent determined a deficiency in petitioners' income tax for the calendar year 1979 in the amount of $5,969. The issues for decision are (1) whether petitioners are exempt from Federal taxation of wages earned from the Panama Canal Commission during the period October 1, 1979, through December 31, 1979, under the Panama Canal Treaty; (2) whether tropical differential payments received by petitioners

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