Legal Opinion

Specking v. Comm'r

United States Tax Court

Decided August 28, 2001No. 12010-99; No. 12348-99; No. 14496-99PublishedCited by 80 opinions

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.

Read the full summary

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

  1. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  2. Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
  3. Gustafson v. Alloyd Co.Supreme Court of the United States · 1995
  4. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  5. Brown v. GardnerSupreme Court of the United States · 1994

15 more not listed; retrieve them via the Exa API.

3Cited by80 opinions

  1. Eric N. Umbach v. Commissioner of Internal Revenue, Joseph D. Specking v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 2004
  2. Arnett v. Comm'rUnited States Tax Court · 2006
  3. Umbach v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
  4. Paul E. Farrell Frances G. Farrell v. United StatesCourt of Appeals for the Ninth Circuit · 2002
  5. Francisco v. Comm'rUnited States Tax Court · 2002

75 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API