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PINO v. COMMISSIONER

Docket No. 22190-83.

52 T.C.M. 1388 (1987)

T.C. Memo. 1987-28

Henry Pino and Lyda Pino v. Commissioner.

United States Tax Court.

Filed January 13, 1987.

Attorney(s) appearing for the Case

Andrew C. Barnard, for the petitioners. Sergio Garcia-Pages, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $13,662 in petitioners' Federal income tax for 1981. After concessions, the issues for decisions are:

1. Whether income earned in 1981 by petitioner Henry Pino as a canal pilot for the Panama Canal Commission is exempt from taxation by the United States.

2. Whether petitioners are entitled to a deduction under section 217(h)

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