MEMORANDUM OPINION
HOLMES, Judge:
Louis Pavich repairs and maintains sophisticated equipment under the direction of U.S. military personnel. He does his work under a contract between the U.S. Government and his employer, Raytheon Co. His pay during the tax years at issue, 1999-2003, was calculated using Raytheon's pay schedules, supplemented by a "Special Offsite Allowance" that Raytheon pays its employees who, like Pavich, spend much of their working life...
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