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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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