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ARNETT v. COMMISSIONER

Docket No. 8866-03.

126 T.C. 89 (2006)

126 T.C. No. 5

DAVE ARNETT, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 25, 2006.

Attorney(s) appearing for the Case

Larry D. Harvey, for petitioner.

Randall L. Preheim, for respondent.

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 on respondent's motion for summary judgment...

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