Valdés v. Secretary of the Treasury

78 P.R. 551
CourtSupreme Court of Puerto Rico
DecidedJuly 29, 1955
DocketNo. 10967
StatusPublished

This text of 78 P.R. 551 (Valdés v. Secretary of the Treasury) is published on Counsel Stack Legal Research, covering Supreme Court of Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Valdés v. Secretary of the Treasury, 78 P.R. 551 (prsupreme 1955).

Opinion

Mr. Justice Belaval

delivered the opinion of the Court.

The case of Postley v. Secretary of the Treasury, 75 P.R.R. 822, 844 (Snyder) (1954), disposes of half of the appeal filed by the Secretary of the Treasury, since in said case we held: that § § 12, 13, 18, and 19 of the Income Tax Act, insofar as they provide (1) a 29 percent normal tax on citizens of the United States who are nonresidents of Puerto Rico as against a 7 percent normal tax on citizens of the United States who are residents of Puerto Rico, and (2) the denial to such citizens of the United States who are [553]*553nonresidents of Puerto Rico of the exemptions and credits for dependents granted to the citizens of the United States who are residents of Puerto Rico, are void because they violate § 2 of the Organic Act of Puerto Rico of 1917.

The taxpayer, as a withholding agent, withheld from the income of certain baseball players, which he brought to Puerto Rico for the 1948 season, the income corresponding to a resident, and the deficiency notified by the former Treasurer of Puerto Rico was based on the income corresponding to a nonresident. All this happened, of course, before our decision in the Postley case. There is only one case, that of the Cuban baseball player Armando Torres, who happens to be a nonresident alien, which is not covered by the Postley case and for whom the withholding agent is liable as to the 29 percent tax pursuant to § 22(a) of the Income Tax Act as amended by Act No. 88 of May 8, 1945.

The second question in issue refers to certain transportation, lodging and meal expenses paid by the employer which he did not include in the income earned by the employee. The evidence showed that the contract executed between the withholding agent and the baseball players was ■a contract for professional services, of a temporary duration, with a specific compensation for professional services exclusively; that during the entire baseball season, the withholding agent paid to his baseball players the salary stipulated for professional services and he also defrayed, on his own account, the transportation, lodging and meal expenses of said players; that this was the established custom in •Puerto Rico in order to obtain the services of the players imported from the United States and the Latin American countries to reinforce the teams; that said contracts were so conditioned because it was convenient for the owner of the team, in order to insure that those players would play for him at the proper time, to have them all living together in a place chosen by the employer himself in order to watch them closely and control their diets for the purpose of keep[554]*554ing them in the best physical condition; that this is customary in United States as well as in Puerto Rico in order to insure a good baseball show and the most profitable income during the baseball season.

The Secretary of the Treasury tries to convince us that those expenses should be regarded as income of the baseball players and added to their respective salaries, pursuant to- § 15(a) of our Income Tax Act, as amended by Act No. 29 of December 8, 1947, and the provisions of § 71 of Regulation No. 1 of the Income Tax Regulations which provides: “When living quarters such as camps are furnished to employees for the convenience of the employer, the ratable value-need not be added to the cash compensation of the employee, but where a person receives as compensation for services-rendered a salary and in addition thereto living quarters, the value to such person of the quarters furnished constitutes-income subject to tax.”

The rules for determining what is known in tax law as “convenience of the employer test” may be very simple or’ very complex. Generally speaking, the travelling expenses for business reasons are considered as an expenditure to-be deducted by whoever pays it. The Income Tax Act is-based on the theory that each person has his home or his place of business within a fixed location which he need not change for another in order to carry on his family life or his business. When the person moves from said location for business reasons, the travelling expenses are deductible as an expense because they are considered necessary for the production or collection of income either for himself or for another person: 2 Federal Taxes (1955) 11,091 and 11,161 § § 11,145 and 11,270 (Prentice-Hall, 1955 ed.) ; 90 L. ed. 213 (1946); Coburn v. Commissioner of Internal Revenue, 138 F. 2d 763, 764 (Swam) (1943); Wallace v. Commissioner of Internal Revenue, 144 F. 2d 407, 410 (McCormick) (1944).

[555]*555This is also the case as to lodging expenses. The law starts from the principle that every person has a home or a business location, post of duty or station, which he need not change for another in order to carry on his family life or his usual business. When the person has to abandon said home or business location for business reasons, the lodging expenses are deductible as an expense because such expenses are considered necessary for the production or collection of income either for himself or for another: 2 Federal Taxes (1955) 11,163, § 11,271 (cited edition); E. G. Leach v. Commissioner of Internal Revenue, 12 Tax Court of United States Reports 20, 21 (Murdock) (1949). The same thing holds for meal expenses.

As may be seen, the important thing is that the traveling expenses for business reasons, such as transportation, lodging or meals, be incurred: (1) for the production or collection of income either for himself or for another; (2) away from home or from the ordinary place of business. There is also another important condition: the travelling expenses for business reasons must be of a temporary duration or for a specific period of time which does not require a change of location or of residence and are not of indefinite duration: 2 Federal Taxes (1955) 11,165, § 11,271-A, (cited edition). The authorities do not distinguish between expenses incurred directly by the person who produces the income for himself or by the person who produces the income for another person, it being the same whether the income accrues to the employee or to the employer: 2 Federal Taxes (1955) 11,161, § 11,270 (cited edition).

Having established the general rules as to traveling-expenses for business reasons, we shall now examine the subject of certain traveling expenses which, although defrayed by the employer in order to produce or increase his own income, may be regarded as income accruing to the employee.

[556]*556We agree that the operative test to be met, in order to exclude or include as additional income of the employee the traveling expenses paid by the employer, is the employer’s convenience and not that of the employee. Whenever the traveling expenses for business reasons are paid by the employer for his own convenience, they do not form part of the employee’s income; whenever they are paid for the personal convenience of the employee, they form part of the employee’s income: 1 Federal Tax Service 7668-7669, § 7704; (Prentice-Hall, 1964 ed.); Federal Tax Course 1309, § 1307, (Prentice-Hall, 1965 ed.); The Federal Income Tax—Stanley and Killcullen 24, § § 29.22 (a) (3) and 22.22 (a) (4), (The Tax Club Press, 1948 ed.); The Federal Income Tax—Stanley and Killcullen 26, § § 29.22(a)(4) (The Tax Club Press, 1951 ed.); 2 Merten’s Law of Federal Income Taxation 74, § 11.16 (Callaghan and Company, 1942 ed.).

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78 P.R. 551, Counsel Stack Legal Research, https://law.counselstack.com/opinion/valdes-v-secretary-of-the-treasury-prsupreme-1955.