- 2 -
Larry D. Harvey, for petitioners.
Randall L. Preheim, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
respondent’s motion for summary judgment pursuant to Rule 121.1
After a concession,2 the sole issue for decision is whether
petitioners can exclude from income wages earned during 2000 from
working in Antarctica.
Background
At the time they filed the petition, petitioners resided in
Lander, Wyoming. During 2000, petitioners performed services at
McMurdo Station in Ross Island, Antarctica. On their 2000
Federal income tax return, petitioners excluded wage income
earned and received during 2000 for services performed in
Antarctica.
1 Unless otherwise indicated, all Rule references are to
the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
year in issue. Respondent has filed similar motions for summary
judgment in dockets of the similarly situated taxpayers who are
U.S. persons who earned income from working in Antarctica.
2 Respondent concedes that no penalty pursuant to sec. 6662
is due from petitioners for 2000.
Page: Previous 1 2 3 4 5 Next
Last modified: November 10, 2007