- 7 - 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 ifPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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