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to their employees. Third, we analyze whether petitioners
furnished the meals at each of the Properties to each of
substantially all of their employees at the Property for the
convenience of the employer. In other words, with respect to
each year, we look at each employee and determine whether section
119 allows him or her to exclude the value of the meals from
gross income, and we then determine whether the number of
employees at each Property who may exclude their meals comprises
substantially all of the employees at that Property. For
purposes of this litigation, the parties have stipulated whether
section 119 excludes the meals of employees in certain job
descriptions. Respondent has conceded that the meals received by
employees in the following job descriptions are excludable under
section 119:
CHC
Casino: Dealer Dice, Dealer 21
Engineering: Maintenance Engineer, Maintenance
Engineer Helper
Food and Beverage: Food and Beverage Director,
Executive Chef, Beverage Manager, Assistant Food
Director, Assistant Chef, Restaurant Manager, Food
Shift Supervisor, Host Person, Sous Chef, Kitchen
Runner, Bus Person, Cashier--Food, Dining Room Runner,
Food Server, Lead Kitchen Help, Kitchen Help, Lead Line
Cook, Line Cook, Prep Cook III, Prep Cook II, Prep Cook
I, Snack Bar Attendant, Special Bus Person, Special
Food Server, Special Lead Line Cook, Special Line Cook,
Banquet Server
MIS: Computer Operator
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