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The Bengalia’s, Husband (H) and Wife (W) filed a joint tax return for 1933-34 in Hawaii. H was a manager of several hotels in Honolulu. H was constantly on duty and as such H and W occupied a suite of rooms in one of the Hotels and received their meals at and from the hotel. H’s salary varied from $9,625 to $25,000 but that was without reference to his meals and lodging, and neither H nor his employer ever regarded the meals and lodging as compensation or accounted for them. The Commissioner added $7,845 each year to H’s gross income as compensation for the suite and meals. Bengalia (P) petitioned the court for review.

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