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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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