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We disagree with petitioner. A taxpayer who resides in
Johnston Island does not qualify for the section 911 exclusion
because Johnston Island is a U.S. possession and not a foreign
country. Section 1.931-1(b)(2), Income Tax Regs., does not
provide otherwise. Thus, income petitioner earned on Johnston
Island is not foreign earned income excludable under section 911.
See Farrell v. United States, F.3d at ; Specking v.
Commissioner, supra at 113-116.
We conclude that petitioner may not exclude from gross
income under either section 931 or section 911 compensation he
earned for personal services he performed on Johnston Island in
1997. See Farrell v. United States, F.3d at ; Specking v.
Commissioner, supra at 111, 116.
To reflect the foregoing,
Decision will be
entered for respondent.
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