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application to them and is obsolete as to petitioners.
Id. at 110-111.
We reject petitioner’s reliance on section 1.931-1, Income
Tax Regs., in the instant case for the same reasons we rejected
the taxpayers’ reliance on that regulation in Specking v. Commis-
sioner, supra.
On the record before us, we find that for the year at issue
petitioner may not exclude under section 931 any of the wages
that he received from Raytheon during that year while he was
residing and working in Johnston Island.6 Specking v. Commis-
sioner, supra; see also Farrell v. United States, 313 F.3d 1214
(9th Cir. 2002).
We turn now to the determination in the notice that peti-
tioner is liable for the year at issue for the accuracy-related
penalty under section 6662(a). According to respondent, peti-
tioner is liable for that penalty because of negligence or
6Petitioner does not rely on sec. 911 in support of his
position that his wage income for 1998 is excludable from his
gross income. For the sake of completeness, respondent nonethe-
less argues on brief that sec. 911 does not entitle petitioner to
exclude his wages for 1998 from his gross income for that year.
We agree with respondent. In Specking v. Commissioner, 117 T.C.
95, 111-116 (2001), affd. sub nom. Haessly v. Commissioner, __
Fed. Appx. __ (9th Cir., June 16, 2003), we rejected the
taxpayers’ alternative argument that, in the event the Court were
to hold that their compensation was not excludable from gross
income under sec. 931, such compensation was excludable under
sec. 911. For the reasons set forth in Specking, we conclude
that sec. 911 does not entitle petitioner to exclude from his
gross income for 1998 the wages that he received during that year
while he was residing and working in Johnston Island. Id.
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