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
OPINION
Vasquez, Judge:
Respondent determined an $8,066 deficiency in petitioner’s 2001 Federal income tax and a $1,613.20 section 66621 penalty. After a concession,2 the sole issue for decision is whether section 911 entitles petitioner to exclude from gross income the wage income he earned in Antarctica in 2001.
This case is before the Court oh respondent’s motion for summary judgment and petitioner’s motion for partial summary judgment under Rule 121. This is the lead case in an unconsolidated group of approximately 150 cases of similarly situated taxpayers who earned wage income in…
2Cases cited11 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
6 more not listed; retrieve them via the Exa API.
3Cited by64 opinions
- Struck v. Comm'rUnited States Tax Court · 2007
- Letourneau v. Comm'rUnited States Tax Court · 2012
- Lemon v. Comm'rUnited States Tax Court · 2007
- Minor v. Comm'rUnited States Tax Court · 2008
- Arnett v. Comm'rUnited States Tax Court · 2006
59 more not listed; retrieve them via the Exa API.