In article ,
Shoulbe wrote:
Section 61.123(h) requires commercial applicants to have already obtained a
private ticket (unspecified) unless they qualify under 61.73 as military pilots
- but then only for the category and class in which those military pilots are
already qualified. So, a student pilot can not proceed immediately to the
commercial level.

Transition pilots can do this (transition from a private ASEL,
for example). And as you mention military. Don't know about foriegn
pilots.

But yes,

(h) Hold at least a private pilot certificate issued under this part or
meet the requirements of Sec. |61.73|

does seem to apply to those who have never held any previous pilot
certificate...

Thanks for the clarification...