Amaro A. Taibo - Page 3

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               On July 6, 1999, a petition was filed in this Court by a               
          Raytheon employee who worked on Johnston Island (first Raytheon             
          employee) in which petition the taxability of wages earned by               
          U.S. citizens on Johnston Island was challenged.  Specking v.               
          Commissioner, docket No. 12010-99.  A regulation, which stated              
          that Johnston Island constituted a U.S. possession for purposes             
          of excluding from taxable income wages earned by U.S. citizens on           
          Johnston Island, formed the basis for the claim of nontaxability.           
          See sec. 1.931-1, Income Tax Regs.1   In subsequent similar cases           
          filed by Johnston Island employees, infra, other employees also             
          rely on this same regulation.                                               
               On July 12, 1999, another petition was filed in this Court             
          by another Raytheon employee who worked on Johnston Island                  
          (second Raytheon employee) in which petition the taxability of              




               1  Sec. 1.931-1, Income Tax Regs., provides in part as                 
          follows:                                                                    
                    � 1.931-1.  Citizens of the United States and domestic            
               corporations deriving income from sources within a                     
               possession of the United States.--(a) Definitions.--(1) As             
               used in section 931 and this section, the term “possession             
               of the United States” includes * * * Johnston Island * * *.            
                         (2) As used in section 931 and this section, the             
                    term “United States” includes only the States, the                
                    Territories of Alaska and Hawaii, and the District of             
                    Columbia.                                                         
                    (b) General rule--(1) Qualifications. In the case of a            
               citizen of the United States or a domestic corporation                 
               satisfying * * * [certain] conditions, gross income means              
               only gross income from sources within the United States                
               * * *.                                                                 




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