Soboleski v. Commissioner
United States Tax Court
During 1980 and 1981, petitioner Joseph N. Soboleski was employed as a civil engineer with the U.S. Army Corps of Engineers. Petitioner was assigned to work in the Kingdom of Saudi Arabia where he supervised the construction of a Saudi Arabian military installation. Held, petitioner's salary was paid by an agency of the United States, and therefore he is not entitled to exclude his salary from taxable income under sec. 911(a), I.R.C. 1954.
1Opinion of the Court
SWIFT, Judge:
In a statutory notice of deficiency dated February 18, 1983, respondent determined deficiencies in petitioners’ Federal income tax liabilities for 1980 and 1981 in the amounts of $9,089 and $3,463, respectively. The issue for decision is whether petitioners may exclude under section 911(a)1 salary payments received by petitioner Joseph N. Soboleski for work he performed in Saudi Arabia as a civil engineer on the construction of a Saudi Arabian military installation.
FINDINGS OF FACT
Many of the facts have been stipulated and are so found. Petitioners timely filed joint Federal…
2Cases cited16 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Krichbaum v. United StatesDistrict Court, E.D. Tennessee · 1956
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- John D. McComish and Genevieve A. McComish v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
- Teskey v. CommissionerUnited States Tax Court · 1958
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