- 12 - 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...)Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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