Arnett v. Comm'r
United States Tax Court
P is a U.S. citizen who earned wage income while working in Antarctica. P excluded this wage income on his 2001 Federal income tax return. R issued a notice of deficiency in which R determined that the excluded wage income earned in Antarctica is taxable. Held: The wage income P earned in Antarctica is not excludable from income under sec. 911, I.R.C.
1Opinion of the Court
DAVE ARNETT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Arnett v. Comm'r
No. 8866-03
United States Tax Court
126 T.C. 89; 2006 U.S. Tax Ct. LEXIS 5; 126 T.C. No. 5;
January 25, 2006, Filed
P is a U.S. citizen who earned wage income while working in
Antarctica. P excluded this wage income on his 2001 Federal
income tax return. R issued a notice of deficiency in which R
determined that the excluded wage income earned in Antarctica is
taxable.
Held: The wage income P earned in Antarctica is not
excludable from income under sec. 911, I.R.C.
Larry D. Harvey, for petitioner.
Randall L. Preheim,…
2Cases cited13 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Stone v. WhiteSupreme Court of the United States · 1937
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