Haessly v. C.I.R.

Full title: Robert J. HAESSLY, Petitioner--Appellant, v. COMMISSIONER OF INTERNAL…

Court: United States Court of Appeals, Ninth Circuit

Date published: Jun 16, 2003

68 F. App'x 44 (9th Cir. 2003)

Opinion

68 Fed.Appx. 44 (9th Cir. 2003) Robert J. HAESSLY, Petitioner--Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent--Appellee. No. 02-71203. IRS No. 14496-99. United States Court of Appeals, Ninth Circuit. June 16, 2003

Submitted June 11, 2003. ^*

* This panel unanimously finds this case suitable for decision without oral argument. See Fed. R.App. P. 34(a)(2).

NOT FOR PUBLICATION. (See Federal Rule of Appellate Procedure Rule 36-3)

Appeal from a Decision of the Internal Revenue Service.

Before SCHROEDER, Chief Judge, D.W. NELSON, and W. FLETCHER, Circuit Judges.

MEMORANDUM ^**

** This disposition is not appropriate for publication and may not be cited to or by the courts of this circuit except as provided by Ninth Circuit Rule 36-3.

Because Treasury Regulation § 1.931-1 does not establish that Johnston Atoll is a foreign country, Haessly cannot claim a deduction pursuant to 26 U.S.C. § 911. All other issues are disposed of by Farrell v. United States, 313 F.3d 1214 (9th Cir.2002), argued by the attorney for the appellant in this matter. The decision of the Tax Court is

AFFIRMED.