Specking v. Comm'r
United States Tax Court
During the years in issue, Ps lived and worked on Johnston Island, a U.S. insular possession. Ps claim that, under sec. 931, I.R.C., they can exclude from gross income the compensation they received for services they performed on that island. HELD: Ps may not exclude from their gross income under sec. 931, I.R.C., the compensation they earned on Johnston Island because that island is not a specified possession as defined in sec. 931(c), I.R.C.
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During the years in issue, Ps lived and worked on Johnston Island, a U.S. insular possession. Ps claim that, under sec. 931, I.R.C., they can exclude from gross income the compensation they received for services they performed on that island. HELD: Ps may not exclude from their gross income under sec. 931, I.R.C., the compensation they earned on Johnston Island because that island is not a specified possession as defined in sec. 931(c), I.R.C. Alternatively, Ps claim that, under sec. 911, I.R.C., and sec. 1.931-1(b)(2), Income Tax Regs., they can exclude from gross income up to $ 70,000 of…
1Opinion of the Court
OPINION
Marvel, Judge:
These cases were submitted fully stipulated pursuant to Rule 122.2 In separate notices of deficiency, respondent determined the following deficiencies with respect to petitioners’ Federal income tax returns:
Joseph D. Specking, docket No. 12010-99
Year Deficiency
1995 . $8,522
Year ■ Deficiency
11,531 CO <y¡ r-i
10,173 oí rH
Eric N. Umbach, docket. No. 12348 — 99
Year Deficiency
1995 . $17,844
1996 . 18,802
1997 . 20,025
Robert J. Haessly, docket No. 14496 — 99
Year , Deficiency
1995 . $17,859
Petitioners3 filed separate petitions to redetermine the deficiencies. We consolidated these…
2Cases cited20 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
- Gustafson v. Alloyd Co.Supreme Court of the United States · 1995
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Brown v. GardnerSupreme Court of the United States · 1994
15 more not listed; retrieve them via the Exa API.
3Cited by80 opinions
- Eric N. Umbach v. Commissioner of Internal Revenue, Joseph D. Specking v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 2004
- Arnett v. Comm'rUnited States Tax Court · 2006
- Umbach v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
- Paul E. Farrell Frances G. Farrell v. United StatesCourt of Appeals for the Ninth Circuit · 2002
- Francisco v. Comm'rUnited States Tax Court · 2002
75 more not listed; retrieve them via the Exa API.