Legal Opinion

Paul E. Farrell Frances G. Farrell v. United States

Court of Appeals for the Ninth Circuit

Decided December 24, 2002No. 01-15435PublishedCited by 16 opinions

1Opinion of the Court

SILVERMAN, Circuit Judge.

We hold today that income earned by a taxpayer on Johnston Island, a U.S. insular possession, is not excludable from gross income as “foreign earned income” under § 911 of the Internal Revenue Code. Neither is it income derived from a source within a “specified possession” as defined by § 931 of the Code. We therefore affirm the district court.

I. FACTS

Between 1994 and 1996, appellant Paul Farrell was employed by Raytheon Corporation. During those years, Farrell lived and worked on Johnston Island, a 591-acre island located approximately 700 miles west-southwest of…

2Cases cited5 opinions

  1. Eric D. Oliver v. Jerry Keller, Sheriff Kyle Edwards Dave SwiekertCourt of Appeals for the Ninth Circuit · 2002
  2. Specking v. Comm'rUnited States Tax Court · 2001
  3. Frank Scofield, Collector of Internal Revenue v. A. J. Lewis and Grace M. LewisCourt of Appeals for the Fifth Circuit · 1958
  4. Richard A. Cramer Alice D. Cramer Warren K. Boynton Susi M. Boynton Kevin P. Monaghan Dina A. Monaghan v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
  5. Microsoft Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2002

3Cited by16 opinions

  1. Haessly v. CommissionerCourt of Appeals for the Ninth Circuit · 2003
  2. Eric N. Umbach v. Commissioner of Internal Revenue, Joseph D. Specking v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 2004
  3. Umbach v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
  4. Tuan Thai, Also Known as Anh Tuan Thai, Also Known as Anh Thai Tuan v. John Ashcroft, Attorney GeneralCourt of Appeals for the Ninth Circuit · 2004
  5. Norman v. United StatesCourt of Appeals for the Federal Circuit · 2019

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