Doran v. Commissioner
United States Tax Court
Held, value of living quarters furnished to the petitioner by his employer was compensation for services rendered and therefore includible in the petitioner's gross income.
1Opinion of the Court
OPINION.
Tietjens, Judge:
Although the petitioner deducted the amount of rental allowance from his total wages on his returns for each of the years in question, his argument and evidence were directed toward showing that his rental was excludible rather than deductible from gross income.
Section 22 (a) of the Internal Revenue Code includes in the definition of gross income “compensation for personal service * * * of whatever kind and in whatever form paid, * * *.” Ordinarily, living quarters provided for an employee in connection with his work are considered a part of the compensation for his…
2Cases cited1 opinion
- Diamond v. SturrDistrict Court, N.D. New York · 1953
3Cited by18 opinions
- Commissioner v. KowalskiSupreme Court of the United States · 1977
- J. Melvin Boykin v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1958
- Romer v. CommissionerUnited States Tax Court · 1957
- Boykin v. CommissionerUnited States Tax Court · 1958
- Saunders v. CommissionerUnited States Tax Court · 1954
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