Amaro A. Taibo - Page 7

                                        - 7 -                                         
          the following information regarding the wages petitioner received           
          in 2000 relating to his work on Johnston Island:                            

               (1) The amount -- $185,048;                                            
               (2) Their character -- petitioner’s wages from Raytheon;               
               (3) Raytheon’s treatment of the wages -- as petitioner’s               
                    wages and as taxable income to petitioner;                        
               (4) The fact that $50,109 in taxes were withheld by                    
                    Raytheon with regard thereto;                                     
               (5) The fact that petitioner on his Federal income tax                 
                    return was claiming an offsetting reduction to the full           
                    $185,048 in disclosed wages and a refund of the $50,109           
                    in withheld taxes relating thereto;                               
               (6) The fact that petitioner worked on Johnston Island and             
                    that petitioner’s Federal income tax return treated               
                    Johnston Island as a “possession”; and                            
               (7) The basis on which petitioner was relying for his                  
                    treatment of his Johnston Island wages as nontaxable              
                    income, namely sec. 1.931-1(a) and (b)(i) and (ii),               
                    Income Tax Regs.4                                                 

               On March 5, 2001, a fourth petition was filed in this Court            
          by a fifth Raytheon employee who worked on Johnston Island in               
          which petition the taxability of wages earned on Johnston Island            
          was challenged.  Jones v. Commissioner, docket No. 2970-01.                 




               4  A partial copy of petitioner’s electronically filed 2000            
          Federal income tax return as printed out by respondent discloses            
          only the information in the first five numbered items in the                
          above list regarding petitioner’s wages earned on Johnston Island           
          and does not reflect the information in the last two above-                 
          numbered items.                                                             





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