- 17 - II. Corporate Automobile Respondent determined that the prorated annual lease value of the corporate automobile furnished to Deborah during 1994 and 1995 constituted additional gross income to Deborah in each of those years. Deborah concedes that the automobile’s prorated annual lease value constituted income to the extent that she used the automobile for personal reasons and did not pay for such personal use. Deborah contends, however, that the automobile’s prorated annual lease value did not constitute income to the extent the automobile was used for business purposes and to the extent she compensated Cox Tomato for her personal use of the automobile. Deborah, however, has cited no provision of the Internal Revenue Code in support of her argument. Section 61(a)(1) provides that gross income includes fringe benefits such as employer-provided automobiles. Sec. 1.61- 21(a)(1), Income Tax Regs. Absent a statutory exclusion, section 61(a)(1) requires that Deborah’s gross income include the full annual lease value of the automobile, prorated for the portion of the calendar year in which the automobile was available to Deborah. Sec. 1.61-21(d)(1)(i), Income Tax Regs. The parties agree that the prorated annual lease value of the automobile is $6,458 for 1994 and $7,750 for 1995. Sec. 1.61-21(d)(2), (4)(i)(A) and (B), and (5)(i), Income Tax Regs.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011