Amaro A. Taibo - Page 9

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          that Johnston Island was not a specified possession for purposes            
          of the income exclusion allowed under section 931.  Respondent              
          did not assert any penalty relating thereto.                                
               A month thereafter, on December 28, 2001, petitioner mailed            
          to respondent a personal check in the amount of $57,709,                    
          reflecting payment of the full $54,139 tax deficiency for 2000              
          determined by respondent, including interest.  In an e-mail sent            
          to respondent on the same day, petitioner reserved his right to             
          file a claim for refund if the pending litigation regarding the             
          taxability of Johnston Island wages was eventually resolved in              
          the taxpayers’ favor.                                                       
               On February 26, 2002, respondent mailed to petitioner                  
          another letter relating to petitioner’s 2000 Federal income tax             
          return in which letter respondent proposed against petitioner for           
          2000 a $10,828 accuracy-related penalty under section 6662(a)               
          relating to petitioner’s claim that his $185,048 in 2000 wages              
          constituted nontaxable income.                                              
               On May 9, 2002, each of the three taxpayers in Specking v.             
          Commissioner, supra, filed appeals of our decision therein, two             
          to the Court of Appeals for the Tenth Circuit and one to the                
          Court of Appeals for the Ninth Circuit.                                     
               On June 4, 2002, a fifth petition was filed in this Court by           
          a sixth Raytheon employee who worked on Johnston Island in which            
          petition the taxability of wages earned on Johnston Island was              
          challenged.  Hautzinger v. Commissioner, docket No. 9501-02.                




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