-2-
ers’ gross income for each such year under section 112.1 We hold
that they are not.
FINDING OF FACTS
Some of the facts have been stipulated and are so found.
At the time petitioners filed the petition in this case,
they resided in Lake Mary, Florida.
During the years at issue, Mr. Hildebran’s employer was Bay
Ship Management, Inc. (Bay Ship Management).2 During those
years, Bay Ship Management contracted with the United States Navy
(Navy) to provide merchant marine3 personnel to work on a ship
known as the Shughart. The Shughart was owned by the Navy and
was operated solely at the expense of the United States by the
Military Sealift Command, which is part of the Navy (Navy Mili-
tary Sealift Command).
During the years at issue, Bay Ship Management assigned Mr.
Hildebran to work for certain periods during those years as a
merchant marine on the Shughart. During 1998, Mr. Hildebran
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
2During the years at issue, Mr. Hildebran was a member of a
union which had contracted with Bay Ship Management regarding
certain union member rights.
3At all relevant times, a professional merchant marine, also
known as a merchant seaman, was a professional mariner who moved
products by ship from one port to another port. At such times,
the duties of a merchant marine included loading and unloading
ship cargo.
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