- 14 - 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).Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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