-2-
Petitioners' entitlement to such exclusion depends upon the
classification (independent contractor vis-a-vis employee) of
Ertan Eren's employment relationship with FBO during the year under
consideration. For the reasons set forth herein, we hold that such
relationship was that of an employee with the consequence that
petitioners are not entitled to the claimed section 911 foreign
earned income exclusion.
All section references are to the Internal Revenue Code for
the year under consideration, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference.
Background
Petitioners Ertan and Susan Eren, husband and wife, resided in
Rockville, Maryland, at the time they filed their petition. They
filed a joint Federal income tax return for 1989.
Ertan Eren is an architect1. He resided in Bogota, Colombia,
from July 1988 through June 1990. At that time, he worked for FBO
as project director for the construction of an annex to the U.S.
Embassy in Bogota.
1 All references to petitioner in the singular will be to
Ertan Eren.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011