- 7 - Antarctica. If Antarctica is not a “foreign country” for purposes of section 911, petitioner must include in income the wage income he earned in Antarctica. IV. Caselaw In Martin v. Commissioner, 50 T.C. 59 (1968), we decided a similar issue--whether a U.S. citizen can exclude income earned in Antarctica. We held that Antarctica is not a foreign country within the meaning of section 911(a)(2) and section 1.911- 1(b)(7), Income Tax Regs., as in effect in 1962. In Martin, the taxpayer, as an employee of a private tax- exempt U.S. organization, took part in an Antarctic expedition. The taxpayer claimed, as does petitioner, that his earnings in Antarctica were exempt from tax under section 911, and the only question raised in this respect in Martin was whether Antarctica is a foreign country. In finding that Antarctica is not a foreign country within the meaning of section 911(a)(2), we relied on a treaty effective June 23, 1961, between the United States and a number of other nations regarding Antarctica. The Antarctic Treaty, Dec. 1, 1959, 12 U.S.T. 794. The treaty provides that Antarctica is to be used for peaceful purposes, that scientific investigation there is to be encouraged, and that all questions of sovereignty over it are to be put in abeyance.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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