- 16 - 1986 of old section 931 was not effective for their taxable year 2001 since certain implementing agreements were not entered into between the United States and the specified possessions identi- fied in section 931 after that amendment; and (2) after the amendment by the TRA 1986 of old section 931 the Treasury did not amend or withdraw section 1.931-1, Income Tax Regs., promulgated under old section 931, and therefore petitioners were entitled to rely on that regulation. Around 6� months before petitioners signed their 2001 joint return,12 we rejected both of those arguments in Specking v. Commissioner, 117 T.C. 95 (2001). As discussed above, in Specking, we held that the amendment of old section 931 by the TRA 1986 became effective as to taxpayers who earned compensation while working on Johnston Island for taxable years that began after December 31, 1986. Id. at 109-110. In so holding, we rejected the argument advanced by the taxpayers in Specking and petitioners here that the existence of certain implementing agreements between the United States and the speci- fied possessions identified in section 931 after its amendment by the TRA 1986 was a condition precedent to the effective date of such amendment of old section 931. Id. As also discussed above, in Specking, we further rejected the argument of the taxpayers there and petitioners here that section 1.931-1, Income Tax Regs., promulgated under old section 931 continued to apply after 12See supra note 6.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011