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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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