FRANCISCO v. C.I.R.

No. 03-1210.

370 F.3d 1228 (2004)

John A. FRANCISCO, Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided June 18, 2004.


Attorney(s) appearing for the Case

R. Todd Luoma argued the cause for appellant. With him on the briefs was Daniel R. King.

Teresa E. McLaughlin, Attorney, U.S. Department of Justice, argued the cause for appellee. With her on the brief was Michael J. Haungs, Attorney.

Before: SENTELLE, ROGERS and GARLAND, Circuit Judges.


Opinion for the Court filed by Circuit Judge SENTELLE.

SENTELLE, Circuit Judge:

John A. Francisco ("Francisco" or "taxpayer"), a citizen of the United States and resident of American Samoa, appeals from a judgment of the United States Tax Court upholding in large part an Internal Revenue Service deficiency notice. The notice assessed Francisco for taxes on earnings he was paid in American Samoa but which he earned while working on a fishing boat in international...

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