Legal Opinion

Joseph S. Bellwood & Jacqueline E. Bellwood v. Commissioner

United States Tax Court

Decided October 7, 2019No. 13226-17Unpublished

1Opinion of the Court

T.C. Memo. 2019-135

UNITED STATES TAX COURT JOSEPH S. BELLWOOD AND JACQUELINE E. BELLWOOD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13226-17. Filed October 7, 2019. In 2013, 2014, and 2015, P-H flew helicopters in Saudi Arabia for a U.S. company that provided air ambulance services for the Saudi Red Crescent Authority. P-H worked in Saudi Arabia on a repeating “28 & 28” schedule, meaning 28 days on duty followed by 28 days off duty. During the 28 days on duty, P-H lived in Saudi Arabia and resided in employer-provided housing when he was not otherwise working.…

2Cases cited18 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  3. HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  4. Hradesky v. CommissionerUnited States Tax Court · 1975
  5. Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000

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