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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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