Mizell v. Commissioner
United States Tax Court
A and B, physicians, were on the staff of H, a hospital. A and B frequently ate in H's cafeteria where, as staff physicians, they exercised their privilege to charge the cost of their meals. A and B also were shareholder-employees of M, a medical professional association, whose offices were in a building adjacent to H. M paid A's and B's monthly H cafeteria meal bills.
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A and B, physicians, were on the staff of H, a hospital. A and B frequently ate in H's cafeteria where, as staff physicians, they exercised their privilege to charge the cost of their meals. A and B also were shareholder-employees of M, a medical professional association, whose offices were in a building adjacent to H. M paid A's and B's monthly H cafeteria meal bills. Held: (1) A and B may not exclude M's monthly meal bill payments from their income under sec 119, I.R.C. 1954. (2) M may not deduct its monthly meal bill payments. (3) M's monthly meal payments are dividends to A and B.
1Opinion of the Court
MYRON W. MIZELL AND KAREN L. MIZELL, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Mizell v. Commissioner
Docket Nos. 27216-83; 27217-83; 27218-83.
United States Tax Court
T.C. Memo 1988-69; 1988 Tax Ct. Memo LEXIS 95; 55 T.C.M. (CCH) 169; T.C.M. (RIA) 88069;
February 23, 1988.
A and B, physicians, were on the staff of H, a hospital. A and B frequently ate in H's cafeteria where, as staff physicians, they exercised their privilege to charge the cost of their meals. A and B also were shareholder-employees of M, a medical professional association, whose offices were in a…
2Cases cited15 opinions
- Sharon v. CommissionerUnited States Tax Court · 1976
- Commissioner v. KowalskiSupreme Court of the United States · 1977
- Joel A. Sharon and Ann L. Sharon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- Sutter v. CommissionerUnited States Tax Court · 1953
- Ma-Tran Corp. v. CommissionerUnited States Tax Court · 1978
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