United States Tax Court July 31, 1974, Docket No. 2728-71 (Solano v. Commissioner)

lead-opinion

OPINION

Simpson, Judge:

The respondent determined a deficiency of $514.17 in the Federal income tax of the petitioner for the year 1969. The issue for decision is whether the petitioner, a United States citizen and bona fide resident of Spain, may exclude the portion of the income which was earned by her husband, a nonresident alien, by the performance of personal services in Spain,