Income Earned While Working in Afghanistan Is Not Excludable

Income Earned While Working in Afghanistan Is Not Excludable

U.S. Tax Court

The Tax Court, sustaining an accuracy-related penalty, held that a couple couldn’t claim the foreign earned income exclusion under <a href="/research/federal/usc26/911" resolve="/lr/resolve/911/cq5z" title="911">section 911</a> for income the wife earned while working in Afghanistan because her abode was in the United States, but the court allowed some depreciation deductions and business expense deductions for the husband’s business.

The Tax Court, sustaining an accuracy-related penalty, held that a couple couldn’t claim the foreign earned income exclusion under section 911 for income the wife earned while working in Afghanistan because her abode was in the United States, but allowed some depreciation deductions and business expense deductions for the husband’s business.

The Tax Court, sustaining an accuracy-related penalty, held that a couple couldn’t claim the foreign earned income exclusion under section 911 for income the wife earned while working in Afghanistan because her abode was in the United States, but the court allowed some depreciation deductions and business expense deductions for the husband’s business.

Sec. 911 Citizens or residents of the United States living abroad

Sec. 162 Trade or business expenses

Sec. 167 Depreciation

Sec. 67 2-percent floor on miscellaneous itemized deductions

Sec. 217 Moving expenses

Sec. 6662 Imposition of accuracy-related penalty on underpayments

United States

Exemptions and deductions

Foreign-source income

Individual income taxation

Penalties

Richard T. Morrison

United States Tax Court

DOC 2019-26882

2019 TNTF 134-20

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Income Earned While Working in Afghanistan Is Not Excludable