Petitioner Eugene W. Goodwillie, Jr. (hereinafter petitioner) is a partner in the New York City law firm of White & Case. In 1978, petitioner was the resident partner in the firm's London, England, office. During that year, in addition to his distributive share of the partnership's income and a guaranteed foreign salary, petitioner received from White & Case a "foreign living allowance" of $9,534 and a "foreign education allowance" of...
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