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days. During 2004 petitioner worked a total of 90 days in
international waters and in foreign ports for a total of 92 days.
Petitioner was not employed in the United States at any time
during the years in issue.
Petitioner filed Federal income tax returns for 2002, 2003,
and 2004 and attached to them Forms 2555-EZ, Foreign Earned
Income Exclusion, claiming that all of his income in those years
was foreign earned income excluded from gross income under
section 911 for Federal income tax purposes. On his 2002 return
petitioner reported $20 in taxable interest and $63,641.48 in
gross wages consisting of:
Wage income (Maersk) $42,235.06
Military retirement pay 14,903.64
Vacation pay 6,502.78
Total 63,641.48
On his 2003 return petitioner reported gross wages of $70,510.66
consisting of:
Wage income (Maersk) $46,295.42
Military retirement pay 15,106.20
Vacation pay 9,078.35
Interest income 30.69
Total 70,510.66
Petitioner received additional interest income of $31 in 2003
that he failed to report. On his 2004 return petitioner reported
$50 in taxable interest and gross wages of $58,992 consisting of:
Wage income (Maersk) $42,567.40
Military retirement pay 6,365.93
Vacation pay 10,058.67
Total 58,992.00
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