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On his 2001 Federal income tax return, petitioner excluded
$48,894 of wage income earned and received as an employee of
Raytheon for services performed in Antarctica during tax year
2001.
In the notice of deficiency, respondent determined that the
income petitioner earned in Antarctica is taxable and is not
excludable under section 911.
Discussion
I. Summary Judgment
Respondent moved for summary judgment on the issue of
whether section 911 entitles petitioner to exclude from U.S.
taxation $48,894 of wage income earned and received as an
employee of Raytheon for services performed in Antarctica during
tax year 2001.
Petitioner moved for partial summary judgment on the issue
of whether the income he earned in Antarctica is foreign earned
income within the meaning of section 911. Petitioner contends
that the income he earned in Antarctica “was not earned from
sources within the United States” and that he should be entitled
to the foreign earned income exclusion under section 911.
Petitioner’s motion is for partial summary judgment because even
if the Court finds for petitioner that the income he earned in
Antarctica is foreign earned income, petitioner must still prove
that he otherwise meets the requirements of section 911.
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Last modified: May 25, 2011