Legal Opinion

Stone v. Commissioner

United States Tax Court

Decided July 31, 1959No. Docket No. 66682PublishedCited by 20 opinions

Held, on the basis of the facts and surrounding circumstances, that camp living quarters and meals furnished to petitioners by their employer at the construction site of a tunnel project in Alaska, were furnished to them "for the convenience of the employer" within the meaning of Regulations 118, section 39.22(a)-3; and that under said regulations, the value of such living quarters and meals are excludible from petitioners' gross income.

1Opinion of the Court

OPINION.

PieRCe, Judge:

Respondent determined a deficiency in the income tax of petitioners for the year 1953, in the amount of $1,387.34.

The sole issue for decision is whether the amount of $3,549, which the Commissioner has included in the petitioners’ income as the value of board and room furnished by their employer at a construction camp in Alaska, should be excluded from income as “living quarters or meals * * * furnished to employees for the convenience of the employer,” within the meaning of Regulations 118, section 39.22(a)-3, relating to the Internal Revenue Code of 1939.

All the facts…

2Cases cited3 opinions

  1. Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
  2. Helvering v. WinmillSupreme Court of the United States · 1938
  3. Olkjer v. CommissionerUnited States Tax Court · 1959

3Cited by20 opinions

  1. Dole v. CommissionerUnited States Tax Court · 1965
  2. Bhalla v. CommissionerUnited States Tax Court · 1960
  3. Anderson v. CommissionerUnited States Tax Court · 1964
  4. Heyward v. CommissionerUnited States Tax Court · 1961
  5. The United States Junior Chamber of Commerce v. The United StatesUnited States Court of Claims · 1964

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