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Commissioner v. Kowalski

United States Supreme Court
434 U.S. 77 (1977)


Facts

The State of New Jersey (state) provided state troopers with meals in kind at meal stations located throughout the state. This system was not ideal for the state, because state troopers would have to leave their patrol areas for extended periods of time. To correct this, the state implemented a policy of providing state troopers with cash meal allowances. Robert Kowalski (plaintiff) was audited for not including the full amount of the cash meal allowances as gross income. The federal tax commissioner (commissioner) (defendant) determined that the cash meal allowance should have been included as gross income. Kowalski petitioned for a redetermination in the United States Tax Court. The tax court ruled for the commissioner. The United States Court of Appeals for the Third Circuit reversed, holding that the allowance was not taxable. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Brennan, J.)

Dissent (Blackmun, J.)

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