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Respondent announced that she would rely upon the deemed
admissions, which we incorporate herein by this reference.4
Discussion
Deficiencies for the Taxable Years in Issue
For purposes of convenience, we will combine our findings of
fact and opinion.
During the years in issue, petitioner resided in Chula
Vista, California, U.S.A. From 1983 through 1985, petitioner
worked as an engineering technician for General Dynamics Corp. in
San Diego, California. In 1983, petitioner worked for Rohr
Industries, Inc., in Chula Vista, California. During 1983, 1984,
and 1985, petitioner received wages from General Dynamics Corp.
in the amounts of $4,729.40, $30,359.84, and $6,206.99,
respectively. Petitioner received $13,223.05 in wages from Rohr
Industries, Inc., in 1983.
On his Federal income tax returns for 1983 through 1985,
petitioner reported these wages and claimed that they were
excludable from gross income as foreign earned income. See sec.
911(a) and (b). Petitioner's apparent position is that the State
of California is not part of the United States. Courts have long
4We have often decided cases on the basis of deemed
admissions. See, e.g., Marshall v. Commissioner, 85 T.C. 267,
271 (1985); Doncaster v. Commissioner, 77 T.C. 334, 336 (1981);
Freedson v. Commissioner, 65 T.C. 333, 335 (1975), affd. 565 F.2d
954 (5th Cir. 1978).
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