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The Tax Court decided two more cases yesterday on whether Antarctica is a foreign country for U.S. tax purposes. As in the prior 52 cases litigated by Larry D. Harvey on behalf of Americans who had been stationed on the cold continent, the court ruled the taxpayer doesn't qualify for the foreign earned income exclusion. These cases were again litigated for the IRS by Mr. Harvey's nemesis, Randall L. Preheim.
Mr. Harvey will have to reorder from the Acme catalog.
Cites:
Barber, T.C. Memo 2007-338
Swanson, T.C. Memo 2007-337
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