Commissioner v. Kowalski

New Jersey (state) shifted from providing state troopers with meals in kind at fixed meal stations to giving them cash meal allowances instead, so troopers wouldn't have to leave their patrol areas; Kowalski (plaintiff) didn't report the full cash allowance as gross income, relying on 26 U.S.C. § 119 and the older common-law convenience-of-the-employer doctrine, which generally excludes meals furnished for the employer's convenience. The Tax Court sided with the Commissioner (defendant) that the cash allowance was taxable, but the Third Circuit reversed, and the Supreme Court granted certiorari.