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compensation they earned on Johnston Island.
Held: Ps may not exclude from gross income under
sec. 911, I.R.C., the compensation they earned on
Johnston Island during the years in issue because
Johnston Island is not a foreign country within the
meaning of sec. 911, I.R.C. See sec. 1.911-2(g) and
(h), Income Tax Regs.
Kenneth W. McWade, for petitioners.
Jonathan J. Ono, for respondent.
OPINION
MARVEL, Judge: These cases were submitted fully stipulated
pursuant to Rule 122.2 In separate notices of deficiency,
respondent determined the following deficiencies with respect to
petitioners’ Federal income tax returns:
Joseph D. Specking, docket No. 12010-99
Year Deficiency
1995 $8,522
1996 11,531
1997 10,173
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. All dollar amounts are rounded to the nearest dollar.
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