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BILLEAUD v. COMMISSIONER

Docket No. 12436-86.

58 T.C.M. 1348 (1990)

T.C. Memo. 1990-59

Hugh J. Billeaud and Beverly P. Billeaud v. Commissioner.

United States Tax Court.

Filed February 8, 1990.

Attorney(s) appearing for the Case

Robert M. Bandy, NCNB Center Tower, Three Rivers, Tex., for the petitioners. Arlene A. Blume, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined deficiencies in petitioners' income tax for tax years 1982 and 1983 in the amounts of $16,234 and $16,440, respectively.

After concession the issue for decision is whether Hugh J. Billeaud is a "qualified individual" eligible for the foreign earned income exclusion under section 911(a).1 Resolution of this issue requires our determining whether...

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