Memorandum Opinion
WHITAKER, Judge:
Respondent determined a deficiency of $10,637.08 in petitioners' Federal income tax for the taxable year ended December 31, 1983. The issue for decision is whether petitioner Jackie Ray Sparks, Sr. (hereinafter referred to as petitioner or Sparks) was physically present in a foreign country or countries for 330 full days during a period of 12 consecutive months for purposes of the foreign earned income exclusion.
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