126 T.C. No. 5
UNITED STATES TAX COURT
DAVE ARNETT, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8866-03. Filed January 25, 2006.
P is a U.S. citizen who earned wage income while
working in Antarctica. P excluded this wage income on
his 2001 Federal income tax return. R issued a notice
of deficiency in which R determined that the excluded
wage income earned in Antarctica is taxable.
Held: The wage income P earned in Antarctica is
not excludable from income under sec. 911, I.R.C.
Larry D. Harvey, for petitioner.
Randall L. Preheim, for respondent.
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