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McDONALD v. COMMISSIONER

Docket No. 6280-74.

66 T.C. 223 (1976)

JAMES H. McDONALD AND AMELIA H. McDONALD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 5, 1976.

Attorney(s) appearing for the Case

Charles Boyce and Tom Rowentree III, for the petitioners.

Stephen R. Takeuchi, for the respondent.

DRENNEN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for the taxable years 1970 and 1971 in the amounts of $3,419.65 and $3,931.82, respectively. The sole issue presented requires our determination as to whether the payment by petitioner James H. McDonald's employer of the costs of petitioners' living accommodations in Tokyo, Japan, constitutes income includable in petitioners' gross income for 1970 and 1971, and if so, to what...

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