- 2 - 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.Page: Previous 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