Paul B. Dietsche - Page 4




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          IV.  Conclusion                                                             
               Accordingly, for the reasons stated in Arnett I, Arnett II,            
          and herein, we conclude that petitioner cannot exclude from gross           
          income wages earned during 2001 and 2002 from working in                    
          Antarctica.                                                                 
               To reflect the foregoing,                                              

                                                  An appropriate order and            
                                             decision will be entered.                
































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