William D. and Yen-Ling K. Rogers, (2009)
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William D. and Yen-Ling K. Rogers, (2009)
T.C. Memo. 2009-111
UNITED STATES TAX COURT WILLIAM D. AND YEN-LING K. ROGERS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3477-07. Filed May 20, 2009.Ps are husband and wife. In 2002 and 2003 they were U.S. citizens residing in Taiwan. R determined deficiencies in Ps' Federal income tax for 2002 and 2003 on the basis that Ps had claimed excessive exclusions under sec. 911, I.R.C., for income Mrs. Rogers earned while working as a flight attendant.Held: Ps claimed excessive exclusions and are liable for deficiencies.William D. and Yen-Ling K. Rogers, pro sese. Emily Giometti, for respondent.MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: This case is before the Court on a petition for redetermination of deficiencies for petitioners' 2002 and 2003 tax years. The issue for decision is whether petitioners are entitled to exclude under section 9111 all wage income Mrs. Rogers earned in 2002 and 2003 while working for United Airlines, Inc. (United), as a flight attendant.FINDINGS OF FACT During 2002 and 2003 petitioners, who are husband and wife, were U.S. citizens residing in Taiwan. Mrs. Rogers was employed by United as a flight attendant based at Hong Kong International Airport. United required Mrs. Rogers to perform preboarding and postarrival se...See the full content of this document
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