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DOUGHERTY v. COMMISSIONER

Docket No. 17759-89.

62 T.C.M. 680 (1991)

T.C. Memo. 1991-442

Elizabeth T. Dougherty v. Commissioner.

United States Tax Court.

Filed September 10, 1991.

Attorney(s) appearing for the Case

William A. Dougherty, 17871 Santiago Blvd., Villa Park, Calif., for the petitioner. Elizabeth L. Carlson, for the respondent.

Memorandum Findings of Fact and Opinion

WRIGHT, Judge.

Respondent determined a deficiency in petitioner's 1982 Federal individual income tax in the amount of $34,476. Petitioner resided in Pennsylvania at the time the petition in this case was filed.

The only issue for decision is whether petitioner's husband was a "qualified individual" for the section 9111 foreign earned income exclusion in the year at issue.

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