Andras Hautzinger - Page 2

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               The issues for decision are:                                           
               (1) Are the wages that petitioner received during 1998 while           
          he was residing and working in Johnston Island excludable from              
          petitioner’s gross income for that year under section 931 or                
          section 911?  We hold that they are not.                                    
               (2) Is petitioner liable for the year at issue for the                 
          accuracy-related penalty under section 6662(a)?  We hold that he            
          is.                                                                         
                                  FINDINGS OF FACT                                    
               Most of the facts have been stipulated by the parties and              
          are so found.                                                               
               At the time petitioner filed the petition in this case, he             
          resided in Aurora, Illinois.                                                
               During the year at issue, petitioner was a resident of                 
          Johnston Island, a possession of the United States located                  
          southwest of Hawaii.                                                        
               During the year at issue, while petitioner was a resident of           
          Johnston Island, Raytheon Demilitarization Company (Raytheon)               
          employed him as a utility worker, for which he received total               
          wages of $67,482.2                                                          


               2Raytheon issued to petitioner Form W-2, Wage and Tax State-           
          ment (Form W-2), for 1998 showing wages of $18,498.18 and a                 
          separate Form W-2 for that year showing additional wages of                 
          $48,983.38.                                                                 






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