On August 18, 2021, the Tax Court issued a Memorandum Opinion in the case of Wood v. Commissioner (T.C. Memo. 2021-103). The primary issues presented in Wood v. Commissioner were whether the petitioner is entitled to exclude from gross income, as “foreign earned income” under IRC § 911(a)(1), the wages she earned while employed as a contractor on a U.S. military base in Afghanistan; and (2) whether the petitioner is liable for a late-filing penalty