Dole v. Commissioner
United States Tax Court
The superintendent, assistant superintendent, and office manager of a corporation engaged in manufacturing woolen cloth were told by their employer to live in company-owned houses located about 1 mile from the mill. The company operated the mill on a 24-hour-per-day basis Monday through Friday and generally operated two shifts on Saturday. The nature of petitioners' jobs made it necessary for them to live in close proximity to the mill.
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The superintendent, assistant superintendent, and office manager of a corporation engaged in manufacturing woolen cloth were told by their employer to live in company-owned houses located about 1 mile from the mill. The company operated the mill on a 24-hour-per-day basis Monday through Friday and generally operated two shifts on Saturday. The nature of petitioners' jobs made it necessary for them to live in close proximity to the mill. A company-owned Cadillac was used by the superintendent. Held: 1. The fair rental value, including cost of utilities, of company-owned houses furnished to…
1Opinion of the Court
DawsoN, Judge:2
Respondent determined the following deficiencies against the petitioners:
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The issues for decision are:(1) Whether petitioners are entitled to exclude from their gross incomes during the taxable years 1958 through 1960 the fair rental value and cost of utilities of company-owned houses furnished to them by their employer, Packard Mills, Inc.(2) Alternatively, and to be decided only if the fair rental value of such lodging is determined to be includable in petitioners’ gross income, whether the fair rental value and cost of utilities of the houses are in the amounts…
2Cases cited7 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. LoBueSupreme Court of the United States · 1956
- Olkjer v. CommissionerUnited States Tax Court · 1959
- Anderson v. CommissionerUnited States Tax Court · 1964
- Heyward v. CommissionerUnited States Tax Court · 1961
2 more not listed; retrieve them via the Exa API.
3Cited by63 opinions
- Vanicek v. CommissionerUnited States Tax Court · 1985
- Melvin v. CommissionerUnited States Tax Court · 1987
- Commissioner of Internal Revenue v. Charles N. Anderson and Grace M. AndersonCourt of Appeals for the Sixth Circuit · 1966
- Ralph A. Wilson and Joanne B. Wilson, His Wife v. United StatesCourt of Appeals for the First Circuit · 1969
- Lindeman v. CommissionerUnited States Tax Court · 1973
58 more not listed; retrieve them via the Exa API.