- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011