- 2 - 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.Page: Previous 1 2 3 4 NextLast modified: March 27, 2008