Sam is an executive with a U.S. corporation. During the current year, he is working in another country. His employer provides a corporation-owned residence for Sam that is located three miles from his office. The residence is far above the standard he was accustomed to in the United States.

However, the employer feels that it is im- portant for Sam to live in luxurious surroundings because of the business image it conveys. Sam is expected to entertain customers and conduct business in the home as is customary in that country, where people are thought to be very status- conscious. The home contains an office that Sam uses in the evenings to transact business over the phone with customers in different time zones. The fair rental value of the home is $48,000. Does Sam have any income from this housing arrangement?

Follow the tax research steps:

1. Establish the facts and determine the issues.

2. Locate the relevant authorities.

3. Assess the importance of the authorities.

4. Reach conclusions, make recommendations, and communicate the result.