Legal Opinion
Eric N. Umbach v. Commissioner of Internal Revenue, Joseph D. Specking v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided January 29, 2004No. 02-9006, 02-9007PublishedCited by 70 opinions
1Opinion of the Court
HARTZ, Circuit Judge.
In these appeals, we decide whether taxpayers Eric N. Umbach and Joseph D. Specking (Taxpayers) may exclude from gross income their compensation earned while working on Johnston Island, a United States possession, in 1995, 1996, and 1997. Taxpayers sought to exclude their compensation under either 26 U.S.C. § 911, which excludes income earned in a foreign country, or 26 U.S.C. § 931, which excludes income earned in a “specified possession” of the United States. We review these legal issues de novo, see Twenty Mile Joint Venture, PND, Ltd. v. Comm’r, 200 F.3d 1268, 1275…
2Cases cited10 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Commissioner v. SchleierSupreme Court of the United States · 1995
- United States v. Wells Fargo BankSupreme Court of the United States · 1988
- United Dominion Industries, Inc. v. United StatesSupreme Court of the United States · 2001
- Specking v. Comm'rUnited States Tax Court · 2001
5 more not listed; retrieve them via the Exa API.
3Cited by70 opinions
- Arnett v. Comm'rUnited States Tax Court · 2006
- Mitchell v. CommissionerCourt of Appeals for the Tenth Circuit · 2008
- Rogers v. Comm'rUnited States Tax Court · 2013
- Lemon v. Comm'rUnited States Tax Court · 2007
- Minor v. Comm'rUnited States Tax Court · 2008
65 more not listed; retrieve them via the Exa API.