-4-
vaccination, receive training in small arms and antiterrorism,
and carry a Department of Defense identification card which
showed his ship assignment and speciality.
At all relevant times, before serving on a Navy Military
Sealift Command ship, like the Shughart, a merchant marine, like
Mr. Hildebran, was required to, and did, sign articles of engage-
ment (articles of engagement) which set forth the merchant
marine’s commitment to follow the orders of the Master (i.e., the
Captain) of the ship even in the event of hostilities and regard-
less of danger. In the event that a merchant marine assigned to
work on a Navy Military Sealift Command ship were to have refused
to sign articles of engagement, that individual would not have
been allowed to work on such a ship.
During the years at issue, Bay Ship Management also assigned
Mr. Hildebran to work for certain periods as a merchant marine on
a ship known as the SS Sandy Bay. During 1998 and 1999, Bay Ship
Management paid Mr. Hildebran a total of $92,548 and $66,424,
respectively, for his work as a merchant marine during those
respective years on the Shughart and on the SS Sandy Bay.
Petitioners timely filed Form 1040, U.S. Individual Income
Tax Return, for each of their taxable years 1998 (petitioners’
1998 return) and 1999 (petitioners’ 1999 return). Petitioners
filed Form 1040X, Amended U.S. Individual Income Tax Return, for
taxable year 1998 (petitioners’ amended 1998 return). In peti-
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