- 5 - at issue to exclude from his gross income under section 931 the wages that he received from Raytheon during that year. In support of that position, petitioner relies on section 1.931-1, Income Tax Regs. Although not altogether clear, it appears that petitioner is arguing that, because section 1.931-1(a)(1), Income Tax Regs., provides that the term “possession of the United States” includes Johnston Island, he is entitled for 1998 to exclude the wages that he received while residing and working there during that year. Respondent counters that petitioner’s wages for the year at issue are not excludable under section 931.3 We agree with respondent. The Treasury Department promulgated section 1.931-1, Income Tax Regs., under section 931 prior to its amendment (old section 931) by section 1272(a) of the Tax Reform Act of 1986 (TRA 1986), Pub. L. 99-514, 100 Stat. 2593.4 Old section 931 permitted citizens of the United States to exclude income derived from sources within possessions of the United States, except Puerto Rico, the U.S. Virgin Islands, and Guam, if certain conditions were satisfied. Although old section 931 did not define the term “possession of the United States”, regulations promulgated under 3Respondent also argues that petitioner’s wage income for 1998 is not excludable under sec. 911. 4The Treasury Department promulgated the last amendment to section 1.931-1, Income Tax Regs., in 1975. T.D. 7385, 1975-2 C.B. 298.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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