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wages in their 2001 joint return.
We consider now petitioners’ third argument in support of
their position that they had a reasonable basis in claiming the
$99,980 exclusion of 2001 wages in their 2001 joint return. As
we understand that argument, petitioners maintain that in claim-
ing that exclusion they relied on the IRS November 13, 2001
letter to Mr. Jordan14 that the IRS sent in response to Mr.
Jordan’s letter to President Bush.15 On the record before us, we
reject any such argument. The record does not establish that
petitioners were even aware of the IRS November 13, 2001 letter
to Mr. Jordan when they signed their 2001 joint return.
In relying on old section 931 and section 1.931-1, Income
Tax Regs., promulgated under old section 931 in claiming the
$99,980 exclusion of 2001 wages in their 2001 joint return,
petitioners not only ignored Specking v. Commissioner, 117 T.C.
95 (2001), and Farrell v. United States, 87 AFTR 2d 2001-1159,
14As stated supra note 3, the record does not disclose who
Mr. Jordan is or his relationship, if any, to petitioners.
15The IRS November 13, 2001 letter to Mr. Jordan stated in
pertinent part:
I am responding to your letter to President George W.
Bush. You asked about the Code of Federal Regulations
(CFR) as it pertains to Johnston Island.
* * * * * * *
I am enclosing 26 CFR 1.931-1. These regulations are
current as of October 24, 2001.
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