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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.
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