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
Drennen, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax for the taxable years 1970 and 1971 in the amounts of $3,419.65 and $3,931.82, respectively. The sole issue presented requires our determination as to whether the payment by petitioner James H. McDonald’s employer of the costs of petitioners’ living accommodations in Tokyo, Japan, constitutes income includable in petitioners’ gross income for 1970 and 1971, and if so, to what extent.
FINDINGS OF FACT
Certain facts have been stipulated by the parties and are accordingly so found.
Petitioners James H. and Amelia…
2Cases cited14 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
9 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Vanicek v. CommissionerUnited States Tax Court · 1985
- Benninghoff v. CommissionerUnited States Tax Court · 1978
- Adams v. United StatesUnited States Court of Claims · 1978
- Bob Jones University v. United StatesUnited States Court of Claims · 1982
- Frensley v. CommissionerUnited States Tax Court · 1982
18 more not listed; retrieve them via the Exa API.