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United States Ninth Circuit


FARRELL v. US, 01-15435

Income earned by a taxpayer on a U.S. insular possession (here Johnston Island) is neither 1) excludable from gross income as "foreign earned income" under Internal Revenue Code section 911, nor 2) income derived from a source within a "specified possession" under section 931.

Appellate Information

  • Decided 12/24/2002
  • Published 12/24/2002

Judges

  • SILVERMAN, Circuit Judge., Before: RYMER, THOMAS and SILVERMAN, Circuit Judges.

Court

  • United States Ninth Circuit

Counsel

  • For Appellant:
  • Kenneth W. McWade, Kailua, HI, for the plaintiffs-appellants.

  • For Appellees:
  • Kenneth W. Rosenberg, United States Department of Justice, Tax Division, Washington, DC, for the defendant-appellee.
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