-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-Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011