Rudolph v. United States

As a reward for high sales performance, Rudolph (plaintiff) received an all-expenses-paid trip to New York consisting of a half-day convention followed by two days of sightseeing and entertainment for himself and his wife, a trip Rudolph himself described as primarily a pleasure trip. After paying a tax deficiency for failing to report the trip's value as income, Rudolph sued for a refund in district court, which ruled for the government; the court of appeals affirmed, and the Supreme Court granted certiorari.