McDonald v. Commissioner
United States Tax Court
Held, the value of lodgings in Tokyo, Japan, furnished petitioner at a discount by his employer, a subsidiary of Gulf Oil Corp., is not excludable from petitioner's income under sec. 119, I.R.C. 1954, and is includable in petitioner's income under sec. 61, I.R.C. 1954. Held, further, the value of the lodgings furnished petitioner is the rental paid by Gulf under arm's-length lease agreements between Gulf and the owner-lessors.
1Opinion of the Court
James H. McDonald and Amelia H. McDonald, Petitioners v. Commissioner of Internal Revenue, Respondent
McDonald v. Commissioner
Docket No. 6280-74
United States Tax Court
66 T.C. 223; 1976 U.S. Tax Ct. LEXIS 115;
May 5, 1976, Filed
Decision will be entered for the respondent.
Held, the value of lodgings in Tokyo, Japan, furnished petitioner at a discount by his employer, a subsidiary of Gulf Oil Corp., is not excludable from petitioner's income under sec. 119, I.R.C. 1954, and is includable in petitioner's income under sec. 61, I.R.C. 1954. Held, further, the value of the lodgings furnished…
2Cases cited15 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Dole v. CommissionerUnited States Tax Court · 1965
- Olkjer v. CommissionerUnited States Tax Court · 1959
- United States v. John William Gotcher Et Ux.Court of Appeals for the Fifth Circuit · 1968
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