John A. Francisco v. Commissioner

119 T.C. No. 20

UNITED STATES TAX COURT JOHN A. FRANCISCO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7670-00. Filed December 19, 2002. 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.…