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entitled to exclude any income for 1995 through 1997 because his
tax home was not in a foreign country, but in a territory of the
United States, and because he was not a bona fide resident of a
specified possession as defined in section 931(c). In the
notices of deficiency, respondent also made certain computational
adjustments to itemized deductions resulting from the adjustments
to income.
Robert J. Haessly
Haessly resided on Johnston Island when he filed the
petition in his case. He was assigned to the JACADS project for
the period March 9, 1994, through at least October 31, 1997.
On his return for 1995, Haessly 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 $95,654 $1,692 1$85,346
1Haessly also claimed a $12,000 adjustment to income for
alimony paid.
Subsequently, Haessly filed a Form 1040X for 1995 on which
he claimed he was entitled to a refund of $17,816 because he
could exclude $95,654 from gross income for that year since he
was “A BONA FIDE RESIDENT OF U.S. POSSESSION JOHNSTON ISLAND”.
With the Form 1040X, Haessly included a Form 4563, Exclusion of
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