Cook v. United States

This case revolves around the application of the foreign-income exclusion provided by section 911 of the Internal Revenue Code, 26 U.S.C. § 911, to the work of an American artist residing and creating abroad. Plaintiff Robert H. Cook, a United States citizen, is a sculptor, long-resident in Rome, Italy, who works in bronze.1 Essentially, he uses a lost wax process, making a model of the sculpture in beeswax reinforced by strips of bamboo. The model is then taken to an outside foundry where it is cast in bronze. Mr. Cook creates his sculptures in his studio in Rome, and then sells them on a…