James A. Nielsen - Page 4




                                        - 3 -                                         
          at the United States-Australian Joint Defense Facility at Pine              
          Gap Air Force Base in Australia (Pine Gap or the base).2                    
               As a condition of his employment with Raytheon at Pine Gap,            
          petitioner was obliged to accept assigned housing as was required           
          by the U.S. Department of the Air Force (Air Force) for personnel           
          working at the base.                                                        
          Assigned Housing in Alice Springs                                           
               The only housing available to petitioner, as a condition of            
          his employment with Raytheon at Pine Gap, was in Alice Springs,             
          Australia.  Alice Springs, a town of approximately 25,000 people,           
          is located in the middle of the Northern Territory of Australia             
          and is surrounded by three deserts.  Alice Springs is not within            
          the physical boundaries of the base but is about 22 miles away.             
               Apart from a prison located 15 miles from Pine Gap, Alice              
          Springs is the closest residential area to the base.  Similar to            
          other towns near military installations, the residents of Alice             
          Springs include both individuals who worked at the base and                 
          individuals who had no employment affiliation with the base.  For           
          those who worked at Pine Gap, transport between Alice Springs and           
          the base was by public bus or privately owned vehicle.                      


               2  “The defense facility was authorized under a treaty                 
          between the United States and Australia that became effective on            
          Dec. 9, 1966.”  Hargrove v. Commissioner, T.C. Memo. 2006-159               
          n.9.                                                                        








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