Crystal K. Abeyta and Ron L. Abeyta - Page 11

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          that there were no adequate facilities at the base.  Respondent,            
          on the contrary, contends that the lodging does not satisfy the             
          three requirements under section 119(c)(2) to constitute a camp.            
          For the reasons stated below, we agree with respondent to the               
          extent that the requirements of section 119(c)(2)(C) have not               
          been satisfied.                                                             
               On the basis of the record in its entirety, the lodging                
          satisfies only the first two requirements under section                     
          119(c)(2).  With respect to section 119(c)(2)(A), we conclude               
          that the lodging was provided on behalf of TRW.  Respondent                 
          argues that because the Form 1099-MISC indicated that the                   
          Department of the Air Force provided the housing, the lodging was           
          not provided by the employer.  We disagree.  Section 119(c)(2)(A)           
          specifically provides that a camp constitutes lodging that is               
          “provided by or on behalf of the employer for the convenience of            
          the employer”.  Although it appears that the Department of the              
          Air Force owned the housing units, such housing was provided only           
          to employees working at the base, which presumably includes                 
          Australian military personnel, U.S. military personnel, and                 
          employees of the institutional contractors working at the base.             
               With respect to section 119(c)(2)(B), we conclude that the             
          lodging was located, as near as practicable, to the base.  Aside            









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