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was involved in a wide range of duties at Mr. Dixon’s residence.
However, petitioner did not show that she could not have
performed the required duties had she lived at another location.
Petitioner introduced no evidence to establish that residing at
Mr. Dixon’s residence was necessary in order for her to perform
properly the duties of cooking and cleaning. Petitioner was
required to work only 15 hours per week at the residence. While
the occupancy agreement required petitioner to live at the
residence, petitioner was not on duty at all times and could have
properly completed her 15 hours of weekly work while residing
elsewhere. Accordingly, petitioner may not exclude the value of
lodging from gross income pursuant to section 119(a).
Because we have determined that the value of the entire 15
hours of work per week is includable in petitioners’ gross
income, we need not allocate the hours worked between meals and
lodging to determine the includable income amount. The original
agreement between petitioner and Mr. Dixon stipulated the value
of services rendered at $13 per hour. After 1 month (4 weeks) of
service, the hourly rate was increased to $15 per hour.
Accordingly, the fair market value of services received by
petitioner for the first 4 weeks that she worked is $13 per hour
and the remaining 11 weeks of work is valued at $15 per hour.
Petitioner worked 15 hours per week for 4 weeks at a value
of $13 per hour, for a total value received of $780.00.
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