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house that he owned in Lake Stevens, Washington,1 paying during
that year $5,882 of mortgage interest and $1,433 of real estate
taxes. Lake Stevens is a city located near the Puget Sound
approximately 35 miles northeast of Seattle, Washington.2
Petitioner’s sole source of income is his wages from Silver
Bay Logging, Inc. (Silver Bay), the primary office of which is in
Juneau, Alaska. Silver Bay employs petitioner as the captain of
its tugboat (the tugboat), the Silver Bay I. Petitioner pilots
the tugboat transporting barges in and through the waters off,
and to the various ports in and around, southeast Alaska. On the
days which he works, petitioner generally must be on or around
the tugboat 24 hours a day.
During 1996, petitioner worked on the tugboat a total of 307
days. Those days and the corresponding locations in which he
worked were as follows:
Dates Days Location
Jan. 1 through Feb. 13 44 Seattle, Washington
Feb. 14 through Feb. 23 10 Ketchikan, Alaska
1 In their stipulations of fact, the parties spell Lake
Stevens with a “ph” instead of a “v”. Petitioner’s accountant
also used that spelling on the face of petitioner’s 1996 tax
return. Our research, however, leads us to conclude that the
preferred spelling of Lake Stevens is with a “v” instead of a
“ph”. We use the preferred spelling throughout this report. We
note that the preferred spelling also appears in petitioner’s
mailing address as shown on both the notice of deficiency and his
1996 Form W-2, Wage and Tax Statement.
2 We have taken judicial notice of this fact.
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