Dan R. and Ann P. Kunze - Page 5

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          IV.  Conclusion                                                             
               Accordingly, for the reasons stated in Arnett I, Arnett II,            
          and herein, we conclude that petitioners cannot exclude from                
          gross income wages earned during 2000 from working in Antarctica.           
               To reflect the foregoing,                                              

                                                  An appropriate order and            
                                             decision will be entered.                























               3(...continued)                                                        
               income earned for services provided in Antarctica.                     
          We take this opportunity to state our agreement with the Court of           
          Appeals’ conclusion set forth above.  See also HCSC-Laundry v.              
          United States, 450 U.S. 1, 6 (1981).                                        





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