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After a concession,2 the sole issue for decision is whether
petitioner John P. Hahn can exclude from income wages earned
during 2000 from working in Antarctica and petitioners can
exclude from income wages earned during 2001 from working in
Antarctica.
Background
At the time they filed the petition, petitioners resided in
Priest River, Idaho. During 2000, petitioner John P. Hahn
performed services at McMurdo Station in Ross Island, Antarctica.
On his 2000 Federal income tax return, petitioner excluded wage
income earned and received during 2000 for services performed in
Antarctica. During 2001, petitioners performed services at
McMurdo Station in Ross Island, Antarctica. On their 2001
Federal income tax return, petitioners excluded wage income
earned and received during 2001 for services performed in
Antarctica.
Discussion
I. Summary Judgment
Rule 121(a) provides that either party may move for summary
judgment upon all or any part of the legal issues in controversy.
Full or partial summary judgment may be granted only if it is
demonstrated that no genuine issue exists as to any material fact
2 Respondent concedes that no penalty pursuant to sec. 6662
is due from petitioner John P. Hahn for 2000 or from petitioners
for 2001.
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Last modified: March 27, 2008