They come in pairs lately, these defeats for Larry D. Harvey’s clients in Tax Court. Twice more yesterday the court ruled that taxpayers working in Antarctica fail to qualify for the foreign earned income exclusion. Each of the 73 defeats has come at the hands of the seemingly-invincible IRS attorney Randall L. Preheim. Even chemically-enhanced Neifi Perez had a better batting average last year.
The judge in all of these cases, Juan Vasquez, was hearing cases in Des Moines this week. His Antarctic experience must have made him feel right at home.
Cites:
Nossaman, T.C. Memo 2008-42
Winslow, T.C. Memo 2008-43
