I’m not sure whether advisers who specialize in the tax issues of expatriates will learn a lot from studying the recent Tax Court decision in the case of Elena Lea Morgan Weschenfelder and Frederick Burkhart Weschenfelder. What they can definitely do is use it as advertising.
Given their jobs as intelligence analysts Elena and Federick are probably smarter than most CPAs and EAs, myself certainly included. Nonetheless, hiring someone with some specialized tax knowledge would have been money well spent. The Tax Court sustained deficiencies of nearly $90k and penalties close to $40k. And those are from the years 2004-2006, meaning the interest will be, as we say, “a number”.
In 2004 and 2005 the couple worked for CACI Premier Technology and Sycoleman Corp. “They lived and worked full time on a military base, living in Republican Guard barracks that had been refurbished by their employer. Petitioners were employed as intelligence analysts. Their jobs involved strategic and tactical intelligence, and they worked with the Iraqi interim Government to help identify threats and to coordinate safe passage and gatherings within the country.”
Then they moved to Germany for much of 2006 doing similar sort of work. The decision has details about the exact dates, but, as you will see that turned out not to be that important…..Read more>>