- 2 - Background The facts of this case were submitted fully stipulated under Rule 122 and are so found. Since 1991, petitioner has resided on Johnston Island, an unincorporated U.S. Territory located approximately 700 nautical miles southwest of Hawaii where petitioner has been employed as an electrical engineer by Raytheon Demilitarization Co. or its successor (Raytheon). On April 30, 1991, petitioner signed an employment agreement with Raytheon, which stated, among other things, that “Johnston Island is not tax exempt; therefore, standard tax obligations apply.” For each of the years 1991 through 1996, on his Federal income tax returns, the record herein does not indicate whether petitioner treated the wages he received from Raytheon as taxable or as nontaxable income. On his timely filed 1997 joint Federal income tax return, petitioner treated the $143,013 in Raytheon wages that he received in 1997 as taxable income, and petitioner paid the $44,629 in taxes relating thereto. On his timely filed 1998 individual Federal income tax return, petitioner treated the $156,741 in Raytheon wages that he received in 1998 as nontaxable income, and petitioner did not pay the Federal income taxes relating thereto.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011