Attorney-at-Law

LIVE FROM KANDAHAR

In Uncategorized on 08/18/2021 at 15:51

No, I’ve not become  a foreign correspondent. Rather, this is the account of the tax court trial of Deborah C. Wood, 2021 T. C. Memo. 103, filed 8/18/21. Deb and seven (count ’em, seven) of her US contractor witnesses testified back in February at the Albuquerque NM trial session, live from Kandahar, 2021 T. C. Memo. 103, at p. 10. I’ve said it before: why have mobile trial sessions, when Zoom covers the world?

Deb is an ex-GI who tried the free world, didn’t like it, and signed up for Afghanistan. Until this week there were plenty of jobs for qualified personnel there. Deb was a logistics specialist right out of high school, a specialty in high demand.

Deb stayed in Afghanistan. She couldn’t leave the base, didn’t learn the local languages because the few locals on base didn’t talk to foreign women, couldn’t open a local bank account or invest locally. She never rented the house she owned in TX; she let her TX car registration lapse but kept her driver license because her job required it.

Judge Albert G (“Scholar Al”) Lauber: “She had a U.S. bank account, but that was necessary to enable her employer to make direct deposit of her paychecks. Opening a local bank account or buying property in Afghanistan would have been impracticable if not impossible, given the requirements of her security clearance and the ban on leaving the base. Petitioner worked 12 hours a day in Afghanistan, with a half-day off every 14 days. Despite the strenuous demands of her work, she managed to have a full social life, including visiting restaurants and shops on the boardwalk, cooking with friends, and pursuing her weightlifting hobby.

“Petitioner had limited family and personal ties to the United States. She was unmarried and had no children; although she visited her parents in Boston occasionally, she spent a significant amount of her vacation time traveling to other foreign countries.” 2021 T. C. Memo. 103, at p. 22.

The “boardwalk” was apparently an on-base area “which consisted of shops and restaurants surrounding a soccer field and encircled by a running track. The boardwalk had a cigar club and a beauty parlor, as well as American chain restaurants, including Popeye’s and TGI Fridays. As petitioner explained, this was a popular place to ‘hang out.’” 2021 T. C. Memo. 103, at p. 6.

I doubt too many grunts hung out there.

But Deb apparently had what we used to call “a good war.” When friends offered her onshore employment, she turned them all down.

“She credibly testified–and we find–that she planned to continue working as an overseas contractor as long as these jobs continue to be available to her.” 2021 T. C. Memo. 103, at p. 9.

Sure, she got paid well over US rates tax free, since Judge Scholar Al gives her almost all her Foreign Earned Income exclusions.

Well, today she can join with the Man from Mumbai: “Kabul town’ll go to hell –Blow the bugle, draw the sword….”

Does somebody at Tax Court actually have a sense of humor?

But this is a nonpolitical blog.

Deborah C Wood 2021 T. C. Memo 103

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