- 17 - the extent of the taxpayer’s effort to assess his proper tax liability. This factor includes in some circumstances the taxpayer’s reasonable and good faith reliance on the advice of a tax professional. Id. Respondent’s burden of production has been met. Petitioner has conceded that he received, but failed to include in gross income, the following amounts of interest income and U.S. military retirement pay in the years in issue: U.S. Military Year Interest Income Retirement Pay 2002 $20 $14,904.00 2003 31 15,106.20 2004 50 15,417.00 Petitioner also concedes that he either failed to report that income on his returns for the years in issue or improperly excluded it as foreign earned income. Because petitioner’s income earned in international waters is includable in his gross income, petitioner also improperly excluded from gross income the following amounts, calculated by multiplying petitioner’s total earned income for each year by the ratio of days worked in international waters to total days worked for that year: Days Worked in Amount Includable Year International Waters in Gross Income 2002 88 (205 total days worked) $20,921.60 2003 115 (204 total days worked) 31,215.60 2004 90 (182 total days worked) 26,023.54Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: March 27, 2008