Francisco, John A. v. Cmsnr IRS

Opinion for the Court filed by Circuit Judge SENTELLE.

SENTELLE, Circuit Judge:

John A. Francisco (“Francisco” or “taxpayer”), a citizen of the United States and resident of American Samoa, appeals from a judgment of the United States Tax Court upholding in large part an Internal Revenue Service deficiency notice. The notice assessed Francisco for taxes on earnings he was paid in American Samoa but which he earned while working on a fishing boat in international waters. For the reasons more fully set forth below, we affirm the judgment of the Tax Court.

I. BaCkground

In tax years 1995, 1996, and…