Frensley v. Commissioner
United States Tax Court
Petitioners (policemen, firemen, magistrates, FAA employees, and maintenance employees) were residents of the Canal Zone during the years at issue. The Canal Zone Government did not allow private ownership of housing or land in the Canal Zone by any United States Government employee. Hence, all lodging and utilities were owned by the Canal Zone Government. The value of rent and utilities was withheld each month from the wages of petitioners.
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Petitioners (policemen, firemen, magistrates, FAA employees, and maintenance employees) were residents of the Canal Zone during the years at issue. The Canal Zone Government did not allow private ownership of housing or land in the Canal Zone by any United States Government employee. Hence, all lodging and utilities were owned by the Canal Zone Government. The value of rent and utilities was withheld each month from the wages of petitioners. Petitioners claimed exclusions under sec. 119, I.R.C. 1954, from their taxable income for the years at issue for the amounts withheld from their wages…
1Opinion of the Court
THOMAS A. FRENSLEY, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Frensley v. Commissioner
Docket Nos. 10354-77, 1981-78, 2182-78, 2286-78, 2287-78, 2349-78, 2350-78, 2401-78, 2524-78, 3105-78, 3176-78, 3222-78, 4470-78, 4506-78, 5318-78, 5876-78, 8239-78, 10026-78, 1124-79, 1791-79, 2078-79, 2758-79, 3120-79, 5886-79, 7688-79, 10768-79, 9741-80, 15113-80, 15920-80.
United States Tax Court
T.C. Memo 1982-399; 1982 Tax Ct. Memo LEXIS 342; 44 T.C.M. (CCH) 481; T.C.M. (RIA) 82399;
July 19, 1982.
Petitioners (policemen, firemen, magistrates, FAA employees, and maintenance…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Dole v. CommissionerUnited States Tax Court · 1965
- Lindeman v. CommissionerUnited States Tax Court · 1973
- McDonald v. CommissionerUnited States Tax Court · 1976
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Darrell F. Brown v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1983
- Crowe v. United StatesUnited States Court of Claims · 1984