- 4 -
III. Conclusion
Accordingly, for the reasons stated in Arnett I, Arnett II,
and herein, we conclude that petitioner cannot exclude from gross
income wages earned during 2000 from working in Antarctica.
To reflect the foregoing,
An appropriate decision
will be entered.
3(...continued)
conclusion that section 911 is not intended to apply to
income earned for services provided in Antarctica.
We take this opportunity to state our agreement with the Court of
Appeals’ conclusion set forth above. See also HCSC-Laundry v.
United States, 450 U.S. 1, 6 (1981).
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