Federal Tax Research 10th Edition by Steven Gill, Gerald Whittenburg, Roby Sawyers, Debra Sanders, William Raabe

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VanDelay, a citizen of the United States but a resident of Dulcinea, is an important sculptor. This year, he came to the United States to appear at an exhibition of his work in San Francisco. The United States has no tax treaty with Dulcinea. Does the $250,000 that VanDelay netted from the show qualify for the I.R.C. § 911 earned-income exclusion