United States Junior Chamber of Commerce v. United States

334 F.2d 660 (1964)

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United States Junior Chamber of Commerce v. United States

United States Court of Claims
334 F.2d 660 (1964)

  • Written by Heather Whittemore, JD

Facts

The United States Junior Chamber of Commerce (the Chamber) (plaintiff) was a nonprofit organization headquartered in Tulsa, Oklahoma, that promoted civic activities for young men. The Chamber was run by a president who acted as chief executive officer and was elected for a one-year term. As the Chamber’s presidents often came from different parts of the country, the Chamber provided a house for the president to live in while in Tulsa. At night, the president of the Chamber would conduct meetings and briefings in the Chamber’s house and would entertain guests in connection with the Chamber’s business. The president was not required to pay rent, and the Chamber did not include the cost of rent in the president’s gross income, as set out in § 119 of the Internal Revenue Code. The Commissioner of Internal Revenue (defendant) determined that the Chamber had improperly excluded the fair rental value of the house from the president’s income. The trial commissioner of the United States Court of Claims disagreed with the Commissioner of Internal Revenue. The trial commissioner found that the president of the Chamber was required to live in the house during his tenure and that the house was part of the Chamber’s business premises because the president conducted official business in the house. The Commissioner of Internal Revenue appealed.

Rule of Law

Issue

Holding and Reasoning (Jones, J.)

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