MEMORANDUM OPINION
SCHATZ, District Judge.
INTRODUCTION
This tax refund action concerns the excludability of the fair rental value of lodging furnished the plaintiff, Richard D. Winchell (hereafter taxpayer), by his employer, Bellevue College. The taxpayer duly filed federal income tax returns for the calendar years 1975 and 1976. Upon examination of said returns, the Commissioner of Internal Revenue determined (1) that the fair market value of...
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