John K. Yamasaki - Page 4




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          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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