Papineau v. Commissioner
United States Tax Court
Income -- Meals and Lodging -- Regulations 111, Section 29.22 (a)-3. -- A partner, who manages a hotel for his partnership and lives at the hotel as a part of his job, has no taxable income from meals and lodging had by him at the hotel.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined a deficiency of $1,690.75 in income tax of the petitioner for 1944 and one of $1,736.97 for 1945. The issue is whether the Commissioner erred by including in the petitioner’s distributive share of the net income of a partnership for each year an amount to represent the estimated value of his board and lodging. The facts have beeen stipulated.
The petitioner filed his individual income tax returns for 1944 and 1945 with the collector of internal revenue for the district of Nebraska. He is an experienced hotel manager.
Castle Hotel, Ltd. is a…
Also in this document: Concurrence.
2Cases cited1 opinion
- Helvering v. Independent Life InsuranceSupreme Court of the United States · 1934
3Cited by16 opinions
- Commissioner of Internal Revenue v. Richard E. And Helen MoranCourt of Appeals for the Eighth Circuit · 1956
- Commissioner of Internal Revenue v. Everett and Mary C. DoakCourt of Appeals for the Fourth Circuit · 1956
- Doak v. CommissionerUnited States Tax Court · 1955
- Commissioner of Internal Revenue v. Thomas Robinson and Elaine RobinsonCourt of Appeals for the Third Circuit · 1959
- Robinson v. CommissionerUnited States Tax Court · 1958
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