Heyward v. Commissioner
United States Tax Court
John T. Heyward was president and principal stockholder of Winnsboro Granite Corporation, and Mary B. Heyward, John's sister, was a minority stockholder but not an employee thereof.
Read the full summary
John T. Heyward was president and principal stockholder of Winnsboro Granite Corporation, and Mary B. Heyward, John's sister, was a minority stockholder but not an employee thereof. Held: Homes owned by Winnsboro Granite and fuel oil used therein furnished John and Mary by Winnsboro Granite in 1955 without charge were not lodgings furnished for the convenience of the employer within the meaning of section 119, I.R.C. 1954, and the respective values thereof are includible in the gross incomes of John and Mary. Value of lodgings determined.
1Opinion of the Court
Drennen, Judge:
In these consolidated proceedings, respondent determined deficiencies in income tax against petitioners for the calendar year 1955 in the following amounts:
[[Image here]]
The only issue is whether petitioner Mary B. ITeyward and petitioner Jolm T. Heyward realized income by reason of occupying rent free two houses owned by Winnsboro Granite Corporation (hereafter called Winnsboro Granite) and by reason of Winnsboro Granite’s furnishing fuel oil for the houses occupied by them.
FINDINGS OF FACT.
Some of the facts have been stipulated and are found as stipulated.
Mary B. Heyward was…
2Cases cited10 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Olkjer v. CommissionerUnited States Tax Court · 1959
- Jones v. United StatesUnited States Court of Claims · 1925
- Chandler v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1941
5 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Dole v. CommissionerUnited States Tax Court · 1965
- Anderson v. CommissionerUnited States Tax Court · 1964
- Huff v. CommissionerUnited States Tax Court · 1983
- McDonald v. CommissionerUnited States Tax Court · 1976
- M. Caratan and Carola Caratan v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
25 more not listed; retrieve them via the Exa API.