Concessions, get it? Larkin v. IRS, T.C. Memo 2017-54 was the strongest case of 2017 for claiming the Foreign Earned Income Exclusion. This is a factually complicated case because four years of tax partnership and individual tax returns were assessed deficiencies by the IRS. Further, the Court set out ten issues, one of which was whether the Foreign Earned Income Exclusion (IRC Section 911) allowed the taxpayers to exclude foreign earned income and housing costs of over $175,0 [...]
