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EREN v. C.I.R.

No. 96-1620.

180 F.3d 594 (1999)

Ertan EREN; Susan Eren, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided June 14, 1999.

Attorney(s) appearing for the Case

ARGUED: James D. McCarthy, Jr., Potomac, Maryland, for Appellants. Patricia McDonald Bowman, Tax Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee. ON BRIEF: Loretta C. Argrett, Assistant Attorney General, Charles E. Brookhart, Tax Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

Before WIDENER and MURNAGHAN, Circuit Judges, and PHILLIPS, Senior Circuit Judge.

Affirmed by published opinion. Judge WIDENER wrote the opinion, in which Judge MURNAGHAN and Senior Judge PHILLIPS concurred.

OPINION

WIDENER, Circuit Judge:

Petitioners Ertan and Susan Eren appeal a U.S. Tax Court decision that Ertan Eren's 1989 income from the U.S. Department of State, Office of Foreign Buildings Operations (FBO) did not qualify for the foreign earned income exclusion of 26 U.S.C. § 911 (§ 911). The tax court found that...

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