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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) 26,023.54
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Last modified: March 27, 2008