- 6 - 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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011