The taxpayer, who was the employee of a company that assembled and sold tour packages, was found to have received a taxable benefit equal to the average cost to the company of airline seats which it chartered when the company provided to the taxpayer, along with other employees, the right to use seats which the company had been unable to sell to customers. It was irrelevant that there were benefits to the company from having its employees acquire first hand knowledge of the facilities at various vacation sites. It also could not be said that the seats had no value to the employee given that she had applied for travel at around that time to the specified sites and given her failure to discharge the onus of proving some other value was more reasonable.
