Legal Opinion

Tougher v. Commissioner

United States Tax Court

Decided February 6, 1969No. Docket No. 4335-67Published

T, an employee of the Federal Aviation Agency (FAA) lived together with his wife and children on Wake Island. They purchased supplies (consisting primarily of groceries) from an FAA commissary for family use, paying cash therefor on a monthly basis. Held, the amounts thus expended for such supplies may not be "excluded" from T's wages as "meals" furnished to him by his employer. Sec. 119, I.R.C. 1954.

1Opinion of the Court

Michael A. Tougher, Jr., and Amelia L. Tougher, Petitioners v. Commissioner of Internal Revenue, Respondent

Tougher v. Commissioner

Docket No. 4335-67

United States Tax Court

51 T.C. 737; 1969 U.S. Tax Ct. LEXIS 195;

February 6, 1969, Filed

Decision will be entered for the respondent.

T, an employee of the Federal Aviation Agency (FAA) lived together with his wife and children on Wake Island. They purchased supplies (consisting primarily of groceries) from an FAA commissary for family use, paying cash therefor on a monthly basis. Held, the amounts thus expended for such supplies may not be…

2Cases cited15 opinions

  1. Dole v. CommissionerUnited States Tax Court · 1965
  2. United States v. Richard D. Morelan and Margaret Morelan, United States of America v. Karl W. ChristeyCourt of Appeals for the Eighth Circuit · 1966
  3. Robert H. Saunders v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1954
  4. Olkjer v. CommissionerUnited States Tax Court · 1959
  5. United States v. Daniel F. Barrett and Margaret G. Barrett Edgar B. Garner and Evelyn T. GarnerCourt of Appeals for the Fifth Circuit · 1963

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