Francisco v. Comm'r
United States Tax Court
Petitioner (P), a U.S. citizen residing in American Samoa, was employed as chief engineer of a fishing vessel that operated primarily in international waters in 1995, 1996, and 1997. Sec. 931(a), I.R.C., provides that a resident of American Samoa may exclude income that is American Samoan source or effectively connected with a trade or business in American Samoa (American Samoan source or effectively connected income). Sec. 931(d)(2), I.R.C., provides that the determination…
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Petitioner (P), a U.S. citizen residing in American Samoa, was employed as chief engineer of a fishing vessel that operated primarily in international waters in 1995, 1996, and 1997. Sec. 931(a), I.R.C., provides that a resident of American Samoa may exclude income that is American Samoan source or effectively connected with a trade or business in American Samoa (American Samoan source or effectively connected income). Sec. 931(d)(2), I.R.C., provides that the determination of whether income is excludable under sec. 931(a), I.R.C., shall be made under regulations prescribed by the Secretary.…
1Opinion of the Court
JOHN A. FRANCISCO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Francisco v. Comm'r
No. 7670-00
United States Tax Court
119 T.C. 317; 2002 U.S. Tax Ct. LEXIS 59; 119 T.C. No. 20;
December 19, 2002, Filed
Decision entered.
Petitioner (P), a U.S. citizen residing in American Samoa, was
employed as chief engineer of a fishing vessel that operated
primarily in international waters in 1995, 1996, and 1997.
Sec. 931(a), I.R.C., provides that a resident of American Samoa
may exclude income that is American Samoan source or effectively
connected with a trade or business in American Samoa (American
Sa…
Also in this document: Concurrence · Vasquez; Concurrence · Beghe; Dissent.
2Cases cited25 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
- Griffin v. Oceanic Contractors, Inc.Supreme Court of the United States · 1982
- Crooks v. HarrelsonSupreme Court of the United States · 1930
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