Milton L. Hildebran and Judy W. Hildebran - Page 4

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          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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