You know by now that I have an affinity for tax opinions and rulings that I consider a little weird. Well, I found another one. Before I give you the holding in this court case, let me set the stage.

During 2001, Dave Arnett was employed to conduct certain research in Antarctica by Raytheon Support Services Co., who was under contract with the National Science Foundation, a U.S. agency. Arnett, a U.S. citizen, resided and performed services at McMurdo Station in Ross Island, Antarctica. On his 2001 Federal income tax return, he excluded $48,894, his wages for services performed in Antarctica, as excludible foreign earned income under Section 911. His dispute with the IRS ended up in the Tax Court.

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