In Rogers v. Commissioner, the Rogers claimed that the salary attributable to hours spent in international airspace, was earned "within a foreign country" within the meaning of Sec. 911(b)(1)(A). But the Tax Court in Rogers focused on Sec. 1.911-2(h), and decided that for purpose of Sec. 911 the airspace over international waters was not airspace over the territory under the sovereignty of any government. As such, airspace over international waters was not within a "foreign country" for purposes of Sec. 1.911-2(h) and Sec. 911 (b)(1)(A).
The same treatment of the international airspace for purpose of Sec. 911 was expressed in Savary v. Commissioner , Clark v. Commissioner and Struck v. Commissioner. The consistency of the Tax Courts treatment of the income in questions as non-foreign source income assures the taxpayer that any in...
... middle of paper ...
.... Commissioner, 473 F.3d 790, 798 (7th Cir. 2007), aff'g 126 T.C. 89 (2006).
Clark v. Commissioner, T.C. Memo. 2008-71
(Kuntz &Peroni, U.S. International Taxation (WG&L Electronic Edition 2010), Sec.A2.03)
Stankee, "IRS Concedes That Concessionaire Profits Were Not Subpart F Income," 11 /. of InVl Tax'n (Mar. 2000). See also General Explanation of the Tax Reform Act of 1986, fn. 22 above, at p. 829, concluding that even though Sec.863(c) excludes from transportation income salaries of airline employees earned on flights between U.S. airports and foreign country airports, income attributable to services performed in the United States or in the U.S. territorial waters is U.S.-source
Rogers v. Commissioner, T.C. Memo. 2009-111, 97 T.C.M. 1573,
Rogers v. Commissioner, T.C. Memo. 2013-77
Struck v. Commissioner, T.C. Memo. 2007-42
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