I.R.C. Section 119: Is Convenience of the Employer a Valid Concept

Present interpretations of the Convenience of the Employer Rule, Section 119 of the Internal Revenue Code, allows a special privilege tax advantage to some employees while denying an exclusion from income to others similarly situated. The authors urge elimination of Section 119 from the Code or, in the alternative, adoption of a new test designed to eliminate the current inequities.