Rudolph v. United States

The petition for certiorari in this case was granted because it was thought to present important questions involving the definition of “income” and “ordinary and necessary” business expenses under the Internal Revenue Code. 368 U. S. 913. An insurance company provided *270a trip from its home office in Dallas, Texas, to New York City for a group of its agents and their wives. Rudolph and his wife were among the beneficiaries of this trip, and the Commissioner assessed its value to them as taxable income.* It appears to be agreed between the parties that the tax consequences of the trip turn upon…