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defense facility) at the Pine Gap Air Force Base (the base). TRW
was a U.S. Government contractor providing services at the
defense facility.
Petitioners were required to accept assigned housing as a
condition of their employment at the defense facility. The
assigned housing was in Alice Springs, Australia, about 22 miles
from petitioners’ workplace at the defense facility, not within
the physical boundaries of the base. Alice Springs was a town of
approximately 28,000 people and included residents who did not
work at the base as well as those who did. The housing in Alice
Springs where petitioners resided was not in a gated community or
an area open only to TRW employees. The housing was scattered
throughout the city on publicly accessible roads adjacent to
homes available to the general public and not within any separate
enclave or area.
Petitioners did not pay any rent or utility expenses for
their homes in Alice Springs during the years at issue. Local
Alice Springs companies provided services such as trash
collection and law enforcement. Petitioners never conducted any
TRW or defense facility business at their homes in Alice Springs.
Petitioners were required to sign closing agreements as a
condition of their employment. In the closing agreements,
petitioners identified TRW as their employer and waived any right
to elect a foreign earned income exclusion under section 911(a)
for the relevant years with respect to the services they would
provide for the defense facility in Australia. They also agreed
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