v2468-78

68 J. Gerber Hoof net vi

case of Arthur J. H. Jolmson, 7 T,

of these cases were promulgated on

the Tax Court.

In its opinion, the Tax Court

taxpayer and the Government aj

much as Sec. 116 I.R.C. does not de

of '^bona fide resident of a foreign

tries", that Treasury Regulations

and 29.211-2 must be looked to to

interpretation of the words thus us(

The pertinent part of the latter

de-cisive of the issue here involved

dent for the purpose of the incom

signed to tax aliens resident in ^

but has been repeatedly held by tl

partment and the Tax Court to i

reverse to citizens of the United Sta

The substantial part of the Sectioi

"^ ^ ^ One who comes to the I

a definite purpose which in it:

promptly accomplished is a t

his purpose is of such a nature

stay may be necessary for its

and to that end the alien mak(

porarily in the United State

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