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During the year at issue, Raytheon required petitioner to
take a two-week leave following each two-month period that he
spent working in Johnston Island. Petitioner usually spent each
two-week leave in Hawaii.
When petitioner arrived for each two-week leave at the
airport in Honolulu, Hawaii, he (1) usually passed through the
section of that airport designated for foreign travelers and
was required to show his passport to U.S. Customs officials and
(2) occasionally was required to complete U.S. Customs forms. In
the event that petitioner or other Raytheon employees did not
have their passports with them, U.S. Customs officials allowed
them to enter Hawaii but directed them to carry their passports
with them upon their next visit to Hawaii.
On April 15, 1999, petitioner filed Form 1040, U.S. Individ-
ual Income Tax Return (return), for his taxable year 1998. In
that return, petitioner reported wage income of $67,482 and
claimed an exclusion from gross income of $67,482. In support of
that claimed exclusion, petitioner attached Form 4563, Exclusion
of Income for Bona Fide Residents of American Samoa (Form 4563),
to his 1998 return. In that form, petitioner claimed that: He
began residing in American Samoa on June 4, 1997; he was residing
there throughout 1998; he did not maintain any home outside
American Samoa during that year; and he was entitled to exclude
from his gross income for 1998 the entire amount (i.e., $67,482)
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