Joseph D. Specking, et al. - Page 8




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          WHICH CAN BE EXCLUDED AS FOREIGN INCOME.”  On or about July 6,              
          1998, respondent issued refunds to Specking for 1995 and 1996 for           
          the amounts claimed.                                                        
               In a notice of deficiency issued to Specking on April 1,               
          1999, respondent determined that Specking was not entitled to               
          exclude any income for 1995 through 1997 because his tax home was           
          not in a foreign country, but in a territory of the United                  
          States, and because he was not a bona fide resident of a                    
          specified possession as defined in section 931(c).  In that                 
          notice of deficiency, respondent also made certain computational            
          adjustments to itemized deductions resulting from the adjustments           
          to income.                                                                  
          Eric N. Umbach                                                              
               Umbach resided in Gillette, Wyoming, when he filed the                 
          petition in his case.  He was assigned to the JACADS project for            
          the period February 5, 1990, through at least June 8, 2000.                 
               On his returns for 1995 through 1997,8 Umbach reported the             
          following wages from Raytheon, income from other sources, and               
          adjusted gross income (not including any exclusions from income             
          under sections 931 or 911):                                                 




               8Umbach filed electronic returns for 1995 and 1996.  The               
          record does not contain a copy of the 1996 return.  We rely on              
          stipulations of the parties and the 1996 Form 1040X for pertinent           
          information relating to the Form 1040 Umbach filed for 1996.                





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