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address of a relative in California in the blanks for “foreign
address” and indicated an applicable period of January 1 to
May 15, 2002.3
During respondent’s audit, petitioners filed with respondent
amended Forms 2555-EZ for 2001 and 2002 indicating a Costa Rica
foreign address for both years and new applicable periods of
November 30, 2000, to November 30, 2001, and May 16, 2001, to
May 15, 2002, respectively, and petitioners cooperated with all
of respondent’s documented requests for information and otherwise
cooperated with respondent.
Respondent’s revenue agent concluded that petitioners did
not have a foreign tax home for 2001 and 2002, and the revenue
agent disallowed the total foreign earned income exclusions
petitioners claimed for each year.
In their briefs, for purposes of calculating their foreign
earned income exclusions for 2001 and 2002, petitioners request
revised applicable periods for 2001 and 2002 respectively of
January 1 to December 31, 2001, and May 6, 2001, to May 5, 2002.
Alternatively, for each year, petitioners request that we apply
whatever applicable periods would maximize petitioners’ foreign
earned income exclusions.
3The record does not explain why petitioners indicated on
their filed Forms 2555-EZ, Foreign Earned Income Exclusion, for
2001 and 2002, respectively, applicable periods of only 11 months
and 4-1/2 months.
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Last modified: May 25, 2011