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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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