-10-
Ship Management.5
On the instant record, we hold that petitioners are not
entitled under section 112 to exclude from their gross income any
of the wages that Mr. Hildebran received from Bay Ship Management
during each of the years at issue for his work as a merchant
marine on the Shughart.
We have considered all of the arguments and contentions of
petitioners that are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing and the concessions of the parties,
Decision will be entered under
Rule 155.
5We note that during the years at issue Mr. Hildebran was a
member of a union which had contracted with his employer Bay Ship
Management. Members of the Armed Forces of the United States are
prohibited from joining labor unions. See 10 U.S.C. sec. 976
(2000).
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