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Petitioner’s reliance on section 911 is misplaced. Section
911(a) allows an exclusion from gross income for foreign earned
income at the election of a qualified individual, defined as an
individual whose tax home is in a foreign country. See sec.
911(d)(1). Petitioner had no foreign earned income and is not a
qualified individual for purposes of section 911(a). Section
911(a) has no bearing on the taxation of petitioner’s receipts.
Petitioner’s reliance on section 861 likewise is misplaced.
Petitioner reads section 861 to provide that items not defined
therein are not subject to tax. Section 861(a)(1) and (3)
provides that interest from the United States and compensation
for labor or personal services performed in the United States
(with exceptions not applicable here) are items of gross income
which shall be treated as income from sources within the United
States. Nothing in section 861 operates to exclude from income
any of petitioner’s receipts.
We hold that petitioner received unreported income of
$25,838, $30,243, and $29,812 during 1990, 1994, and 1996,
respectively.
II. Schedules A and C Deductions
Petitioner asserted that he was entitled to Schedule A,
Itemized Deductions, and Schedule C, Profit or Loss From
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