Louis M. Pavich - Page 1

                                 T.C. Memo. 2006-167                                  

                               UNITED STATES TAX COURT                                

                           LOUIS M. PAVICH, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 11502-04, 20581-04.    Filed August 15, 2006.              

               Louis M. Pavich, pro se.                                               
               Christopher S. Kippes, for respondent.                                 

                                 MEMORANDUM OPINION                                   

               HOLMES, Judge:  Louis Pavich repairs and maintains                     
          sophisticated equipment under the direction of U.S. military                
          personnel.  He does his work under a contract between the U.S.              
          Government and his employer, Raytheon Co.  His pay during the tax           
          years at issue, 1999-2003, was calculated using Raytheon’s pay              
          schedules, supplemented by a “Special Offsite Allowance” that               

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