SPARKS v. COMMISSIONER

Docket No. 7057-86.

53 T.C.M. 818 (1987)

T.C. Memo. 1987-244

Jackie Ray Sparks, Sr. and Lola Sparks v. Commissioner.

United States Tax Court.

Filed May 11, 1987.


Attorney(s) appearing for the Case

Jackie Ray Sparks, pro se. Timothy Burgmeier, for the respondent.


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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