- 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 NextLast modified: November 10, 2007