Edward D. Clark - Page 2

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                    Year           Deficiency         Sec. 6662(a)                    
                    2002           $11,459             $2,291.80                      
                    2003           12,491              2,498.20                       
                    2004           9,506               1,901.20                       
          After concessions, the issues for decision are:                             
               (1) Whether for the years in issue petitioner may exclude              
          from gross income wages earned while working in international               
               (2) whether for the years in issue petitioner may deduct at            
          Federal per diem rates meal expenses that petitioner did not pay            
          or incur; and                                                               
               (3) whether for the years in issue petitioner is subject to            
          accuracy-related penalties pursuant to section 6662(a).                     
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect during the years in issue,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner resided in Scotland, the United Kingdom, when he filed           
          his petition.                                                               
               Petitioner is a citizen of the United States but resided in            
          Scotland during the years in issue.  Petitioner was employed at             
          various times during the years in issue by Maersk Line, Ltd.                

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Last modified: March 27, 2008