Myron R. Struck and Thelma C. Struck - Page 6

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               During 2001 and the first half of 2002, in California Myron            
          and Thelma also maintained bank accounts, registered and garaged            
          two vehicles at a relative’s property, and maintained their                 
          driver’s licenses.                                                          
               Myron and Thelma’s combined salaries from their employment             
          on the yacht totaled $82,768 for 2001 and $71,063 for 2002.                 
               On petitioners’ 2001 joint Federal income tax return,                  
          petitioners reported their total $82,768 in salaries, and they              
          claimed the foreign earned income exclusion with regard to that             
          total amount. With the filing of their 2001 joint Federal income            
          tax return, petitioners included a Form 2555-EZ, Foreign Earned             
          Income Exclusion, relating to each petitioner.  On these Forms              
          2555-EZ, petitioners entered the address of a relative in                   
          California in the blanks for “foreign address” and indicated an             
          applicable period of January 1 to November 30, 2001.                        
               On petitioners’ 2002 joint Federal income tax return,                  
          petitioners reported their total $71,063 in salaries, and they              
          claimed the foreign earned income exclusion with regard to                  
          $55,120 thereof (based on the number of days in petitioners’ 2002           
          applicable period that fell within petitioners’ 2002 taxable                
          year).                                                                      
               With the filing of their 2002 joint Federal income tax                 
          return, petitioners included a Form 2555-EZ relating to each                
          petitioner.  On these Forms 2555-EZ, petitioners entered the                






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