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employer. The Court has construed the phrase “on the business
premises” to mean either: (1) Living quarters that constitute an
integral part of the business property, or (2) premises on which
the company carries on some of its business activities. See Dole
v. Commissioner, supra at 707 (holding that employees living in
company-owned housing 1 mile away from where they worked did not
constitute living on the business premises of their employer).
In addition, section 119(c) provides that:
an individual who is furnished lodging in a camp
located in a foreign country by or on behalf of his
employer, such camp shall be considered to be part of
the business premises of the employer.
Section 119(c)(2) further provides that a camp constitutes
lodging which is:
(A) provided by or on behalf of the employer for the
convenience of the employer because the place at which
such individual renders services is in a remote area
where satisfactory housing is not available on the open
market,
(B) located, as near as practicable, in the vicinity of
the place at which such individual renders services,
and
(C) furnished in a common area (or enclave) which is
not available to the public and which normally
accommodates 10 or more employees.
Petitioners contend that their lodging was on the business
premises of Mr. Abeyta’s employer because their lodging
constituted a “camp” within the meaning of section 119(c).
Petitioners argue that their residence was in a remote location
completely for the benefit and convenience of the employer and
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