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Tony, a nonresident alien, owns and breeds race horses. Tony enters his star horse in the Kentucky Derby, the Preakness Stakes and the Belmont Stakes,

Tony, a nonresident alien, owns and breeds race horses. Tony enters his star horse in the Kentucky Derby, the Preakness Stakes and the Belmont Stakes, where he wins some purses. While in the United States, Tony buys and sells 100 shares of Proctor & Gamble stock for a tidy profit. Assuming Tony

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