Teddy R. and Cheryl D. McGinty, Jr. - Page 8

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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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