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any other court, and this opinion shall not be treated as
precedent for any other case.
This matter is before the Court on respondent’s Motion For
Summary Judgment, filed December 15, 2006, pursuant to Rule 121.
In his motion, respondent moves for a summary adjudication in his
favor on the substantive issue presented by this case; namely,
whether petitioner is entitled under section 119 to exclude from
gross income the value of lodging provided to him by his employer
during 2000 and 2001. On February 27, 2007, petitioner filed an
Objection to respondent’s motion.
For the reasons discussed below, we shall grant respondent’s
motion.
Background
Petitioner’s Employment
At all times relevant to this case, petitioner was employed
by Raytheon E-Systems, Inc. (Raytheon), an institutional
contractor with U.S. Department of Defense (DOD) agencies.
Raytheon assigned its employees, including petitioner, to work on
specific projects associated with DOD agencies.
During 2000 and 2001, the taxable years in issue, petitioner
was assigned by Raytheon to a position at the Joint Defense
Facility at Pine Gap/Joint Defense Facility at Nurrungar located
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