United States Court of Claims
81-2 USTC ¶ 9689 (1981)
Security Industrial Insurance Company (Security) offered each of its agents the opportunity to bring along his or her spouse on an optional all-expenses-paid trip if the agent increased his or her sales by $600 in the preceding year. Elvia McCann (plaintiff) qualified and took this trip with her husband (plaintiff) in 1973. The trip was entirely free to the McCanns and included airfare, lodging, meals, cocktails, shows, and various other forms of entertainment. The trip lasted three days, and there was only a single mandatory business seminar that lasted two hours. The McCanns did not report the trip as income on their 1973 tax return. The Internal Revenue Service (IRS) audited the 1973 return and determined that the trip should have been included in the McCanns’ gross income. The McCanns paid the deficient amount plus interest. After the IRS denied their claim for relief, the McCanns brought suit against the United States government (defendant), seeking reimbursement.
Rule of Law
Holding and Reasoning
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