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OPINION
VASQUEZ, Judge: Respondent determined an $8,066 deficiency
in petitioner’s 2001 Federal income tax and a $1,613.20 section
66621 penalty. After a concession,2 the sole issue for decision
is whether section 911 entitles petitioner to exclude from gross
income the wage income he earned in Antarctica in 2001.
This case is before the Court on respondent’s motion for
summary judgment and petitioner’s motion for partial summary
judgment under Rule 121. This is the lead case in an
unconsolidated group of approximately 150 cases of similarly
situated taxpayers who earned wage income in Antarctica and who
make similar arguments.
Background
At the time of the filing of the petition, petitioner
resided in Hayward, Wisconsin. During 2001, petitioner was
employed by Raytheon Support Services Co. (Raytheon). Raytheon
is under contract with the National Science Foundation (NSF), an
agency of the United States, for certain research conducted in
Antarctica. During 2001, petitioner, a U.S. citizen, resided and
performed services at McMurdo Station in Ross Island, Antarctica.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
2 Respondent conceded that no penalty pursuant to sec. 6662
is due from petitioner for 2001.
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Last modified: May 25, 2011