2
MEMORANDUM OPINION
K�RNER, Judge: Respondent determined deficiencies in
petitioners' Federal income tax for the years 1988, 1989, and
1990 in the respective amounts of $22,641, $14,864, and $12,568.
Petitioners timely filed their 1988, 1989 and 1990 U.S.
Individual Income Tax Returns, Forms 1040, as married filing
jointly. Pursuant to an extension of time agreed to by
petitioners and respondent for the year 1988, the statutory
notice of deficiency with respect to the taxable years 1988, 1989
and 1990 was timely mailed to petitioners on November 16, 1992.
This case was submitted under Rule 122. The stipulation of
facts and the attached exhibits are incorporated herein by this
reference. All statutory references are to the Internal Revenue
Code in effect for the years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure, except as
otherwise noted.
Petitioners were residents of Brussels, Belgium, when they
filed their petition. Patricia Adair is a party to this
proceeding solely by virtue of having filed joint income tax
returns with her husband; consequently, all references to
petitioner hereinafter will be to William H. Adair. The
controversy for decision is whether section 911 exempted
petitioner from taxation as to a portion of his income during the
years in issue while performing services for the North Atlantic
Treaty Organization (NATO) as a transferee from the U.S. Army.
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