                                   126 T.C. No. 5                                     


                               UNITED STATES TAX COURT                                


                             DAVE ARNETT, Petitioner v.                               
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8866-03.             Filed January 25, 2006.                


                    P is a U.S. citizen who earned wage income while                  
               working in Antarctica.  P excluded this wage income on                 
               his 2001 Federal income tax return.  R issued a notice                 
               of deficiency in which R determined that the excluded                  
               wage income earned in Antarctica is taxable.                           
                    Held:  The wage income P earned in Antarctica is                  
               not excludable from income under sec. 911, I.R.C.                      


               Larry D. Harvey, for petitioner.                                       
               Randall L. Preheim, for respondent.

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