John K. Yamasaki - Page 2




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          After a concession,2 the sole issue for decision is whether                 
          petitioner can exclude from income wages earned during 2000 from            
          working in Antarctica.                                                      
                                     Background                                       
               At the time he filed the petition, petitioner resided in               
          Tucson, Arizona.  During 2000, petitioner 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.                  
                                     Discussion                                       
          I.  In General                                                              
               Section 61(a) provides that gross income means all income              
          from whatever source derived.  Accordingly, citizens of the                 
          United States generally are taxed on income earned outside the              
          geographical boundaries of the United States unless the income is           
          specifically excluded from gross income.  Specking v.                       
          Commissioner, 117 T.C. 95, 101-102 (2001), affd. sub nom. Haessly           
          v. Commissioner, 68 Fed. Appx. 44 (9th Cir. 2003), affd. sub nom.           
          Umbach v. Commissioner, 357 F.3d 1108 (10th Cir. 2003).                     
          Exclusions from income are construed narrowly, and taxpayers must           
          bring themselves within the clear scope of the exclusion.  Id.              




               2  Respondent concedes that no penalty pursuant to sec. 6662           
          is due from petitioner for 2000.                                            






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