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waive his or her right to any election under Code
section 911(a) for the income specified herein for the
taxable period(s) * * *
* * * * * * *
NOW IT IS HEREBY DETERMINED AND AGREED for Federal
income tax purposes that:
(a)(1) the said taxpayer shall not at any time
during or after his or her presence in Australia make
any election under Code section 911(a) with respect to
income paid or provided to said taxpayer as
consideration for services performed for the employer
at the JDSRF/JDSCS in Australia; and
(2) the said taxpayer irrevocably waives and
foregoes any right that he or she may have to make any
election under Code section 911(a) with respect to
income paid or provided to said taxpayer as
consideration for services performed for the employer
at the JDSRF/JDSCS in Australia; * * *
* * * * * * *
(2) the said taxpayer agrees to attach a copy of
this closing agreement to his or her United States
Income Tax Return.
As another condition of his employment, TRW required Mr.
Abeyta to accept assigned housing as was required by the
Department of the Air Force for personnel working at the base.
The only housing available was in Alice Springs, Australia.
Alice Springs is located in the middle of the Northern Territory
of Australia and is surrounded by three deserts. At that time,
the town had a population of approximately 24,000 people. Aside
from a prison located 15 miles from the base, Alice Springs,
which is approximately 22 miles from the base, is the closest
residential area. Similar to other towns near a military
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Last modified: May 25, 2011