Boleslaw D. Kalinski and Dorothy M. Kalinski v. Commissioner of Internal Revenue, Carol Marie Schmidt v. Commissioner of Internal Revenue

McENTEE, Circuit Judge.

In their federal income tax returns for the year 1969 appellants excluded from gross income amounts earned as employees of the United States Air Force Europe (USAFE) Child Guidance Center in Wiesbaden, Germany. 1 The Commissioner determined that these amounts were not excludable under Int.Rev.Code § 911(a)(2) 2 and asserted deficiencies for each of the appellants. 3 The Tax Court found for the Commissioner and the taxpayers appeal. The resolution of this case depends on whether the center at which taxpayers worked is covered by the language of § 911(a)(2) which excepts…