T.C. Memo. 2007-179
UNITED STATES TAX COURT
DAN R. AND ANN P. KUNZE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8174-04. Filed July 5, 2007.
Ps, along with approximately 150 similarly
situated taxpayers, are U.S. persons who earned income
from working in Antarctica. On their Federal income
tax return, Ps excluded income earned during 2000 from
working in Antarctica. R issued a notice of deficiency
for 2000 in which R determined that the income Ps
earned during 2000 from working in Antarctica is not
excludable from income.
Held: The income Ps earned in Antarctica is not
excludable from income pursuant to I.R.C. sec. 911.
Arnett v. Commissioner, 126 T.C. 89 (2006), affd. 473
F.3d 790 (7th Cir. 2007), followed.
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Last modified: November 10, 2007