United States Tenth Circuit
UMBACH v. COMM'R OF INTERNAL REVENUE, 02-9006, 02-9007
Neither 26 U.S.C. section 911, which excludes income earned in a foreign country, nor 26 U.S.C. section 931, which excludes income earned in a "specific possession" of the US, permits plaintiffs to exclude from gross income compensation earned while working on Johnston Island, a US possession.
Appellate Information
- Decided 12/11/2003
- Published 01/29/2004
Judges
- HARTZ, Circuit Judge., Before MURPHY, HARTZ and McCONNELL, Circuit Judges.
Court
- United States Tenth Circuit
Counsel
- For Appellant:
- Kenneth W. McWade, Kailua, HI, for Petitioners-Appellants.
- For Appellees:
- Eileen J. O'Connor, Assistant Attorney General, David English Carmack and Kenneth W. Rosenberg, Attorneys, Tax Division, Department of Justice, Washington, DC, for Respondent-Appellee.