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When underway, every 4 hours Myron would note in a log the
yacht’s longitude and latitude coordinates.
Except for approximately 2 weeks when on vacation in the
United States, and even when docked in foreign ports, Myron and
Thelma lived on the yacht.
Based on testimony and exhibits in evidence, including a
review of the log coordinates that was performed by personnel of
the U.S. Navy for purposes of this case, the charts below set
forth (for Myron and Thelma’s taxable years 2001 and 2002) our
findings as to the number of days during the applicable 12-month
periods on which Myron and Thelma were not physically present in
foreign territorial waters and the number of days they were
physically present in foreign territorial waters.1
As indicated in the charts, the two 12-month applicable
periods we utilize to establish petitioners’ 330 or more days of
foreign physical presence requisite to qualify Myron and Thelma
for the foreign earned income exclusion for 2001 and 2002 overlap
each other and do not correspond to calendar years.
1We refer to each period of 12 consecutive months used in
the calculation of a taxpayer’s foreign earned income exclusion
as an “applicable period”.
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Last modified: May 25, 2011