Kevin L. and Victoria L. Hargrove, et al. - Page 4

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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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