Bold Corporation paid $25 to each full-time employee at year-end in recognition of the holidays….

Bold Corporation paid $25 to each full-time employee at year-end in recognition of the holidays. Bold Corporation is interested in whether the amounts are taxable income to its employees, and whether the company can deduct the amounts.

A partial list of research sources is

• Secs. 74(c), 102, 132(c), and 274(b)

• Reg. Sec. 1.132-6(e)(1)

• Hallmark Cards, Inc. v. U.S., 9 AFTR 2d 391, 62-1 USTC ¶9162 (DC-Mo, 1961).

• Rev. Rul. 59-58, 1959-1 CB 17.

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