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D. Summary
Section 911 does not apply to the compensation petitioners
received for personal services performed on Johnston Island.
Accordingly, we sustain respondent’s determination that
petitioners may not exclude from their gross income for the years
in issue under section 911 any of the compensation they received
for the personal services they performed on Johnston Island.
Conclusion
We have carefully considered all remaining arguments made by
petitioners for contrary holdings, and, to the extent not
discussed, we find them to be irrelevant or without merit.
To reflect the foregoing,
Decisions will be entered for
respondent in docket Nos. 12010-99
and 12348-99.
Decision will be entered under
Rule 155 in docket No. 14496-99.
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