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SANTOS v. COMMISSIONER

Docket Nos. 1173-09, 5323-09.

135 T.C. 447 (2010)

NORMA A. SANTOS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 18, 2010.

Attorney(s) appearing for the Case

Michael J. Low and Jonathon M. Morrison , for petitioner.

Jon D. Feldhammer and Melissa C. Quale , for respondent.

RUWE, Judge:

Respondent determined deficiencies of $4,346 and $6,126 in petitioner's 2005 and 2006 Federal income taxes.1 The only issue for decision is whether petitioner's 2005 and 2006 wages are exempt from taxation because she came to the United States for a period "not expected to exceed 2 years" as contemplated by the Convention With Respect to Taxes on Income, U.S.-Phil., art. 21...

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