117 T.C. No. 9
UNITED STATES TAX COURT
JOSEPH D. SPECKING, ET AL.,1 Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 12010-99, 12348-99, Filed August 28, 2001.
14496-99.
During the years in issue, Ps lived and worked on
Johnston Island, a U.S. insular possession. Ps claim
that, under sec. 931, I.R.C., they can exclude from
gross income the compensation they received for
services they performed on that island.
Held: Ps may not exclude from their gross income
under sec. 931, I.R.C., the compensation they earned on
Johnston Island because that island is not a specified
possession as defined in sec. 931(c), I.R.C.
Alternatively, Ps claim that, under sec. 911,
I.R.C., and sec. 1.931-1(b)(2), Income Tax Regs., they
can exclude from gross income up to $70,000 of the
1Cases of the following petitioners are consolidated
herewith: Eric N. Umbach, docket No. 12348-99; and Robert J.
Haessly, docket No. 14496-99.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011