Stephen Jones - Page 6




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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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