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RICHARD v. COMMISSIONER

Docket No. 40780-86.

55 T.C.M. 864 (1988)

T.C. Memo. 1988-217

James R. and Linda L. Richard v. Commissioner.

United States Tax Court.

Filed May 16, 1988.

Attorney(s) appearing for the Case

Claude T. Allen, 7709 Long Point, Houston, Tex., for the petitioners. Thomas N. Thompson, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Respondent determined a deficiency of $6,527 against petitioners for the 1983 taxable year. The only issue we must decide is whether James R. Richard (hereinafter Mr. Richard or petitioner) was a "qualified individual" within the meaning of section 911(a)1 thereby entitling petitioners to the foreign earned income exclusion...

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