Case Comm v Anderson
In the case of Commissioner of Internal Revenue v Charles N. Anderson, the court sought to review the decision upheld by the tax court regarding the exclusion of meal and lodging services from gross income provided by employers to compensate employees. The tax court had initially decided that the meals and lodging services would be excluded from the taxpayer gross income because the meals furnished and lodging provided were primarily because it occurred on the “business premises of the employer” so it would be excludible from gross income. However further details appeared as the lodging services were not on business premises but actually were two blocks away at a location where the employer built for the taxpayer to stay close proximity within his employment location. The court had to review the decision and come to a new agreement.
The relevant facts of the case were that the location and primary residence of the taxpayer was furnished by the employer for the sole reason of being in close proximity with his employment location which was two short blocks away from the residential property. The acceptance of the residential property of the employee was mandatory and a part of his condition of employment. The meals furnished by the employer consisted of groceries to be given to the employee’s family. The court agreed that they had come to a consensus upon the agreement that the employer business premises was in fact by definition, a residence owned by an employer which qualified the taxpayer’s (Charles Anderson) residence to fall under, thus qualifying the taxpayer from excluding the meals and lodging from his gross income.
The issue arising is not the mandatory agreement that the meals and lodging must be furnished by the employers on his business premises; the court had agreed that the taxpayer and employer fulfilled that argument. However the