- 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