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from gross income for a citizen of the United States who
satisfied the statutory residency test in a foreign country or
countries for “amounts received from sources without the United
States (except amounts paid by the United States or any agency
thereof) which constitute earned income [as defined in section
911(b)] attributable to services performed” during the required
period. In addition, section 911(a)(2) provided a limited
exclusion from gross income for a citizen of the United States
who was present in a foreign country for a certain minimum time
period for amounts received from sources without the United
States which constituted earned income attributable to services
performed during that period. See Miller v. Commissioner, 52
T.C. 752, 757 (1969). Congress imposed certain limitations and
restrictions on the amounts that could be excluded under section
911(a)(1) for services performed after December 31, 1962. See
Revenue Act of 1962, Pub. L. 87-834, sec. 11, 76 Stat. 1003-1006;
see also Hills v. Commissioner, 72 T.C. 958, 962-963 (1979).
Subsequently, for taxable years beginning after December 31,
1977, Congress limited the application of section 911 to
individuals residing in camps located in hardship areas and
provided a deduction in section 913 for certain living expenses
for a taxpayer who had a tax home in a foreign country and who
satisfied the statutory residency or presence tests. See Foreign
Earned Income Act of 1978, Pub. L. 95-615, secs. 201-203, 209(a),
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