West Headnote of the Day – December 10, 2009

December 10, 2009

West's Key 220 Internal Revenue
West's Key 220V Income Taxes
West's Key 220V(X) Income from Within and Without the United States
West's Key 220V(X)2 Income from Sources Without the United States
West's Key 220k4107 Earned Income of Citizens or Residents of the United States
West's Key 220k4110 k. Residence or Presence in Foreign Country.

Antarctica was not “foreign country,” as that term was employed in regulation of Internal Revenue Service (IRS) governing exclusion of income earned while in foreign country; considering Antarctica to not be “foreign country” was compatible with general statutory scheme, sovereignty was essential component of definition of “foreign country” but United States did not recognize any claims of sovereignty over Antarctica, and narrow construction was required to avoid construction which would have excluded more income than Congress intended.
Arnett v. C.I.R., 473 F.3d 790 (7th Cir. 2007)

220 Internal Revenue