Tougher v. Commissioner
United States Tax Court
51 T.C. 737 (1969)
Michael Tougher (plaintiff) was an employee of the Federal Aviation Administration (FAA) and was stationed on Wake Island in the Pacific Ocean. Tougher and his wife purchased groceries at a commissary for FAA employees instead of eating free or reduced-price meals at the FAA mess hall. The Toughers excluded from their gross income the amount they spent on groceries. The Toughers asserted that the exclusion was appropriate under § 119 of the Internal Revenue Code, which allows exclusions from income for employer-provided meals. The Commissioner of Internal Revenue (the commissioner) (defendant) assessed a deficiency in the Toughers’ income-tax return based on the Toughers’ exclusion of their grocery expenditures. The Toughers challenged the commissioner’s determination in United States Tax Court.
Rule of Law
Holding and Reasoning (Raum, J.)
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