Teddy R. and Cheryl D. McGinty, Jr. - Page 12

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          and lodging she received.                                                   
               The value of meals furnished to an employee by his employer            
          shall be excluded from the employee’s gross income if (1) the               
          meals are furnished on the business premises of the employer, and           
          (2) the meals are furnished for the convenience of the employer.            
          Sec. 119(a).  If an employer provides meals to an employee                  
          without charge as a means of providing additional compensation to           
          the employee (and not for a substantial noncompensatory business            
          reason of the employer), the meals are not regarded as furnished            
          for the convenience of the employer, and the value of the meals             
          is included in the employee’s gross income.  Sec. 1.119-                    
          1(a)(2)(i), Income Tax Regs.                                                
               Here, petitioner was furnished meals as compensation for               
          services that she provided.  The meals petitioner received were             
          not additional compensation; the meals were part of her total               
          compensation.  The meals provided to petitioner were not for a              
          substantial noncompensatory business reason of her employer.                
          Accordingly, the meals furnished to petitioner were not for the             
          convenience of Mr. Dixon, and the value of the meals may not be             
          excluded from gross income pursuant to section 119(a).                      
               The value of lodging furnished to an employee by his                   
          employer shall be excluded from the employee’s gross income if              
          (1) the lodging is furnished on the business premises of the                
          employer, (2) the lodging is furnished for the convenience of the           





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