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Eric N. Umbach,3 docket No. 12348-99
Year Deficiency
1995 $17,844
1996 18,802
1997 20,025
Robert J. Haessly, docket No. 14496-99
Year Deficiency
1995 $17,859
Petitioners filed separate petitions to redetermine the
deficiencies. We consolidated these cases for purposes of
briefing and opinion pursuant to Rule 141(a) because they present
common questions of fact and law. These cases in the aggregate
are referred to as “this case”.
After a concession,4 the only issue remaining for decision
is whether petitioners may exclude from gross income, under
section 931 or, alternatively, under section 911, compensation
they received during the years in issue for services they
performed on Johnston Island.
3For 1997, petitioner Eric N. Umbach (Umbach) filed a joint
Federal individual income tax return with Alicia LePard. She did
not join with Umbach in filing the petition for 1997. In the
notice of deficiency for 1997, respondent refers to Alicia LePard
as Alicia Lepard Umbach.
4Respondent concedes that petitioner Robert J. Haessly is
entitled to claim a credit for child and dependent care expenses
in the amount of $43 for 1995.
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