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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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