Stephen Jones - Page 2

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          on Johnston Island, a U.S. possession in the Pacific Ocean.1  We            
          hold that he may not.  See Farrell v. United States,    F.3d   ,            
          (9th Cir., Dec. 24, 2002); Specking v. Commissioner, 117 T.C. 95,           
          111, 113, 116 (2001), on appeal (10th Cir., May 9, 2002).                   
               Unless otherwise specified, section references are to the              
          Internal Revenue Code as amended.  Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      
               All of the facts have been stipulated and are so found.  The           
          parties submitted the case fully stipulated under Rule 122.                 
          Petitioner resided in Melbourne, Florida, when he filed the                 
               Petitioner was employed by Raytheon Engineers &                        
          Constructors, Inc. (Raytheon), on Johnston Island throughout                
          1997.  Petitioner received wages of $83,842 from Raytheon in                
          1997.  On his individual income tax return as amended for 1997,             
          petitioner excluded from his gross income all of the wages that             
          he received from Raytheon in 1997 on the grounds that those wages           
          were excludable under section 931 or section 911.                           

               1  Johnston Island is a U.S. possession.  Act of Aug. 18,              
          1856, ch. 164, 11 Stat. 119, 48 U.S.C. secs. 1411-1419 (2000).              
          Johnston Island is not part of American Samoa, Guam, or the                 
          Commonwealth of the N. Mariana Islands.  Specking v.                        
          Commissioner, 117 T.C. 95, 97 (2001).                                       

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