Haessly v. Comm’r, 68 F. App’x 44 (9th Cir. 2003), and aff’d sub nom. Umbach v. Comm’r, 357 F.3d 1108 (10th Cir. 2003).Section 911(a)(1) provides that a “qualified individual” may, subject to limitations set forth in subsection (b)(2), elect to exclude from gross income his or her “foreign earned income.”