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From January to August 1998, Mr. Pilgram was stationed at a
U.S. Navy base in Sigonella, Sicily. At the end of August, Mr.
Pilgram commenced sea duty aboard the U.S.S. Enterprise, a
nuclear-powered aircraft carrier. Mr. Pilgram remained at sea
until his retirement from the U.S. Navy.
From January to May 1998, petitioner and Randy lived on the
U.S. Navy base in Sigonella with Mr. Pilgram. At the end of May,
petitioner and Randy returned to the United States for medical
reasons. Upon their return, petitioner and Randy lived with
petitioner’s parents in Port Richey, Florida. Thereafter, at the
end of August, petitioner and Randy obtained family housing at
the Naval Air Station in Jacksonville, Florida, where they lived
for the balance of 1998.
Throughout their married life, petitioner and Mr. Pilgram
typically filed joint Federal income tax returns. For 1998,
however, they filed separate returns. They did so only after
petitioner consulted with a military tax preparer at the
Jacksonville Naval Air Station. The military tax preparer
advised petitioner that because Mr. Pilgram was deployed at sea,
it would be advantageous for them to file separately, with
petitioner utilizing head-of-household filing status. Based on
this advice, and utilizing commercial tax preparation software,
petitioner prepared and filed her own return and prepared and
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