This section contains the nature of the case and procedural background.

An insurance company provided a trip to New York for its agents and wives. Rudolph (P) and his wife were among the beneficiaries, and the Commissioner assessed the value of the trip as taxable income. P qualified for the trip by selling a predetermined amount of insurance. One morning of the trip was devoted to business and a group luncheon and rest of the time was for entertainment. The company paid the expenses with P’s share being allocated at $560. The District Court held the trip to be a bonus for a job well done and thus the costs were personal and deductible. This appeal resulted.

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