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included Johnston Island.8
Section 1272(a) of the TRA 1986 amended old section 931 to
exclude from income, in the case of an individual who is a bona
fide resident of a specified possession during the entire taxable
year, gross income derived from sources within any such specified
possession. Section 931, as amended by section 1272(a) of the
TRA 1986, defines the term “specified possession” to mean only
Guam, American Samoa, and the Northern Mariana Islands. Sec.
931(c).
Around 6� months before petitioners signed their 2001 joint
return,9 we issued our Opinion in Specking v. Commissioner, 117
8Sec. 1.931-1, Income Tax Regs., promulgated under sec. 931
prior to its amendment by the TRA 1986 provided in pertinent
part:
� 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 American Samoa, Guam, Johnston Island,
Midway Islands, the Panama Canal Zone, Puerto Rico, and
Wake Island. * * *
On Apr. 6, 2005, the Treasury Department promulgated T.D.
9194, 2005-20 I.R.B. 1016, which revised sec. 1.931-1, Income Tax
Regs., promulgated under old section 931. Subsequent to that
revision, sec. 1.931-1, Income Tax Regs., provides in pertinent
part: “� 1.931-1. Exclusion of certain income from sources
within Guam, American Samoa, or the Northern Mariana Islands.--
[Reserved].”
9Although the record establishes the date on which petition-
ers signed their 2001 joint return, the record does not disclose
(continued...)
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