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Petitioners note that section 162 "does not define
what constitutes an expense", and argue that the term
"expense" should be "the converse of income". Petitioners
further note that under section 61 gross income means all
income "whether received in the form of money, property,
or services." Therefore, according to petitioners, a
deductible expense should include any expenditure made
"in the form of money, property, or services."
Petitioners support their contention that the value of
services is deductible under section 162 by noting that
under section 132, an employee is not entitled to exclude
from gross income a fringe benefit consisting of a service
provided by his or her employer unless the fringe benefit
qualifies as a "no-additional-cost service", as defined by
section 132(b). Petitioners reason that the employee could
not receive income in the form of services "unless the
employer is incurring an equal expense in the form of the
services * * * rendered to the employee".
Petitioners attempt to further support their
contention that the value of services is deductible under
section 162 by noting that section 162(a)(1) allows the
deduction of "a reasonable allowance for salaries or other
compensation for personal services actually rendered".
Petitioners argue that "the term 'other compensation'
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