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438 (2001).
We note at the outset that gross income refers to all
income, from whatever source derived, including compensation for
services. Sec. 61(a)(1). Gross income includes income realized
in any form, whether in money, property, or services. Sec. 1.61-
1(a), Income Tax Regs. When services are paid for in property or
in exchange for other services, the fair market value of such
property or other services must be included in income as
compensation. Sec. 1.61-2(d)(1), Income Tax Regs. The
stipulated price of services rendered will be presumed to be the
fair market value of the compensation received in the absence of
evidence to the contrary. Id.
It is clear that petitioner received money, meals, and
lodging in exchange for services she provided to Mr. Dixon.
Consequently, the money received and the value of the meals and
lodging received are includable in petitioners’ gross income
unless specifically excludable under a provision of the Internal
Revenue Code.
Petitioner concedes that the money she received from Mr.
Dixon is includable in gross income. However, petitioner asserts
that the value of the meals and lodging furnished by Mr. Dixon is
excluded from gross income, pursuant to section 119(a). Section
119(a) provides for the exclusion from an employee’s gross income
of the value of meals or lodging furnished by the employer if
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