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Adams v. United States

United States Court of Claims
585 F.2d 1060 (1978)


Facts

Mobil Sekiyu Kabushiki Kaisha (Mobil), a Japan-based company, owned a residence that its chief executive officer (CEO) had been required to reside in for over 15 years. The residence was specifically designed so that the CEO could conduct business and host social events outside of normal business hours. In Japanese culture, social status and appearance directly affected business perception. Faneuil Adams (plaintiff) was the CEO of Mobil and lived in the company-provided residence. On his tax returns, Adams reported the yearly average U.S. rental rate as his gross income, instead of the fair market rental rate of the Japanese home. The rental rate of the Japanese home was significantly higher than the U.S. average. Adams was audited, and paid the deficient tax. Adams brought suit against the United States government (defendant) to recover the amount paid.

Rule of Law

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Issue

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Holding and Reasoning (Per curiam)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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