- 3 - 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 * * *.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011