Paul E. Farrell Frances G. Farrell v. United States
Court of Appeals for the Ninth Circuit
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…
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