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the 1954 Code; however, the law was changed under
amendments enacted by the Tax Reform Act of 1986.
Johnston Island is not a “specified possession” for
purposes of new section 931, so income earned on the
Island is not subject to exclusion.
The IRS published Publication 570, Tax Guide for Individuals
with Income From U.S. Possessions, for use in the preparation of
individual tax returns for the taxable year 2001 (IRS Publication
570 for 2001). IRS Publication 570 for 2001 stated in pertinent
part:
For 2001, the possession exclusion applies only to
individuals who are bona fide residents of American
Samoa. * * *
Individuals in the following U.S. possessions or
territories are not eligible for the possession exclu-
sion discussed here.
* * * * * * *
• Johnston Island
Sometime prior to November 13, 2001, an individual named
Brian Jordan (Mr. Jordan)3 sent a letter to President George W.
Bush (Mr. Jordan’s letter to President Bush). That letter stated
in pertinent part:
Subject: CFR 26, Vol 10, Part 1, (secs 1.908 to
1.1000), Revised as of 1 April 1997
Dear Sir:
I would like to know if the above mentioned subject is
still current for Johnston Atoll (Island) because I
3The record does not disclose who Mr. Jordan is or his
relationship, if any, to petitioners.
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Last modified: May 25, 2011