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the period June 16, 1993, through at least March 22, 2000.7
On his returns for 1995 through 1997, Specking reported the
following wages from Raytheon, income from other sources, and
adjusted gross income (not including any exclusions from income
under sections 931 or 911):
Income from Adjusted
Year Wages other sources gross income
1995 $74,552 1($15,895) $58,657
1996 85,385 (18,203) 67,182
1997 95,246 (28,211) 67,035
1The negative numbers result from a Schedule F, Profit or
Loss From Farming, farm loss Specking sustained in each year.
With the 1997 return, Specking included a Form 2555, Foreign
Earned Income, on which he claimed that he had foreign earned
income of $95,246 relating to work performed on Johnston Island,
of which $70,000 was an eligible “foreign earned income
exclusion”.
On or about June 1, 1998, Specking filed Forms 1040X,
Amended U.S. Individual Income Tax Returns, for 1995 and 1996 on
which he claimed he was entitled to refunds of $8,522 and
$11,531, respectively, because he could exclude $70,000 from
gross income for each of those years because “UNDER SECTION 931
AND REGULATION 1.931-1 PERSONS EARNING INCOME FROM JOHNSTON
ISLAND ARE CONSIDERED TO HAVE EARNED INCOME FROM A FOREIGN SOURCE
7Specking previously had been assigned to the JACADS project
between Aug. 22, 1988, and Nov. 20, 1991.
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