William H. Adair and Patricia Adair - Page 32

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                  Accordingly, since the only issue presented in this case was                          
            the right of petitioner to take advantage of the foreign earned                             
            income exclusion of section 911(a)(1) because of his compensation                           
            for serving as a member of NATO, and since respondent has                                   
            conceded that issue if we decide, as we have, that petitioner was                           
            an employee of NATO and not of the United States, a recomputation                           
            of petitioners' tax liability for the years 1988, 1989, and 1990                            
            will be necessary, and                                                                      
                                                       Decision will be entered                         
                                                under Rule 155.                                         

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