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Penalty
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
waters;
(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