Joseph D. Specking, et al. - Page 2




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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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