Hatt v. Commissioner

28 T.C.M. (CCH) 1194 (1969)

From our private database of 46,000+ case briefs, written and edited by humans—never with AI.

Hatt v. Commissioner

United States Tax Court
28 T.C.M. (CCH) 1194 (1969)

SR
Play video

Facts

Herbert G. Hatt (plaintiff) met and married Dorothy Echols, the president and majority stockholder of the Albert Johann and Sons Company (Johann). Johann was an Indiana corporation that ran a funeral home in Evansville, Indiana. After Hatt and Echols married, Echols transferred a majority of her shares to Hatt and made him president and general manager of Johann. Hatt moved in with Echols, who lived in an apartment in the same building as the funeral home. An ambulance crew, which the funeral home oversaw, also lived in the building. After business hours, Hatt handled business calls and met with customers in his apartment. Evidence showed that it was customary in the area for funeral homes to have someone live in the same building as the funeral home in order to accommodate customers. Although Hatt received a financial benefit from living in the apartment, he did not include the value of that benefit in his gross income for tax purposes, believing it fell within an exclusion for employer-provided lodging. The commissioner of Internal Revenue (defendant) disagreed, finding the exclusion inapplicable because the lodging was not necessary for Hatt's employment. The commissioner therefore assessed a tax deficiency for the years in which Hatt lived in the apartment. Hatt filed a challenge to the commissioner's determination in the United States Tax Court.

Rule of Law

Issue

Holding and Reasoning ()

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 742,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 742,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 46,000 briefs, keyed to 986 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 742,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 46,000 briefs - keyed to 986 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership