JFK Assassination System Date: 6/14/201 Identification Form Agency Information Peleased under the John Kennedy CIA AGENCY : WSssassination Records RECORD NUMBER : 104-10107-10191 ollection Act of 1992 (44 USC 2107 Note). RECORD SERIES: JFK asef# iN 53216 Date: 6-14-2017 AGENCY FILENUMBER: 80T01357A Document Information ORIGINATOR: CIA - FROM: TO: TITLE: COLLINS RADIO DATE: 01/01/1977 PAGES: 21 SUBJECTS : / "NBR DOCUMENT TYPE: PAPER - TEXTUAL DOCUMENT ‘ { CLASSIFICATION : > Not Marked _ RESTRICTIONS: — Open in Full CURRENT STATUS: — Release DATE OF LAST REVIEW: = 06/14/2017 OPENING CRITERIA : COMMENTS : JFK38 : F24 : 1998.08.04.11:49:29:123081 : NOT BELIEVED RELEVANT (NBR) THERE ARE 4 VOI HW 532716 DBocld:32356065 ee OR Sl POR er DOCUMENTS; THEY WERE DECLARED "NBR" BY THE ARRB, IN ACCORDANCE WITH THE ARRB MEMO DATED 8 OCTOBER 1997. Page 1
\. . (HW 53216 , it is @ conditien of Exp ‘pay not elect #\ cue oe | P. Dalles My Texas Dear Mr, Lewis > Mr. RI Vice President, Acninistration Wy £¢ NO Se . on , foe . : Y ~ REC) ° Cu e th ror 7? MAR TO? ere : Te ton ty ah Sy <e ire leit:c234/ 4 € Levis IV Electresysteus, Inc. C. Box G18 75222 : This ig in reply to your request for ruling dated December 15, Wheiucr the valne of the bachelor enployecs under tha circunstances income for tac purposes. The pertinent Sects LIV Electresystens nS, with the U.S. Govcrasent see povees Worvdng at in dustrelia. The installation is in a 1,090 niles fron the nesrest city of any sine. nearer to tho installation is Alice Sprvi Goverment requixes: all prine dota en ee employees to be “available for da qperters eecigned to thea by t assigned roons ia assigned Specific houses asJat ddLIty of @11 expley red ay a ne U.S, jn Alice Sprin rewulations Co not pomart Sanity renbers we ot ssigucd to ther. to lees Section 6 of the Tnteraz), Revere Coste inecore ieans Pensation for services other “ise exe): sour Nate by Jaz, ave co derived, inélucing ces Css Docld:32358065 Page 2 2 you present m ces is such thot all quarters “» e for marricd caplosees, would te on tho bas Royce that eiployess live in Tey. are givea no choice 3 select sh allovence in lieu of quarters, SCy purchas ‘€or build houses ox apariacats on their ora, quarters supplied to your ust be considered subniited are as follos: Inc. is a subcontiactor wider & prime contract ead has cpproximately sey & joint United States and Ansty ‘alien installation eveuly-Live (75) renote Locition. approximately Tne erg cost towa ngs, which has @ population of approxiaatoly 9,000, Alice Sprinss is ) 15 wiles from the installation and is. the only towa Within Courting Gistance,. .. 0. pee ie g - “Because the’ ‘installation opsrates on # 2hehowx basis, the U.S, 7 *s and their subcontractors! ¥y time and that taployees live Y covert. Dechelors are GQ's on the installation end married ex wloyces ere Se Tre necad for i; . denecklate including S@ CxCEDt that securit; tw live on the inste Wletion,. the qierters bien of the gu: urters, 4 and are n0% allowed ; provides thet, unless ieee fron vhatever te
tire ReL. Lewis Section 119 of the Code provides, in pertinent part, that there shall be excluded froa 6ross incowe of an caployee the valve of any’ lodging furnished to hia by his exployer for the convenience of the cuployer, out only if the Cuployce is requixed to accept such Lodging on the business prenises of his cuployer as a condition of his eploy- mont. oS Section 1.119-lib) of the Income Tex Regulations provides that th value of lodsing furnished to an eaployee by tho caployer shell be ex- ‘& P3 C) 7 o) cluded from the employee's gross incone if these tests are nets 2. The lodging is furnished on the business premises of the employer,’ . . 2. The lodging is furnished for the convenicace of tho - employer, and . 3. The employee is required to accept such ledging as a condition of his employnont. “Based solely on the representations made, we conclude that these three tests are met. Coapare Exasple (7) of scetion 1.119-1(d) of the Regulations. Ynercfore, the value of the lodging furnished to your employees cithcr in the installation barracks or in.the city houses ds excludeble fron the gross incone of such enployees. Sincerely yours, . - a a ‘ </. etl opp erGamte fr He ALY - ChieL, Corporation Tax Branch:
UA a ad re ree See) tbe ee - Mee Renn Dla regiy retin ty F an AR Vem OND, ] ' mom ee Mele i. A te be ele Coch Meeey WS saecep ee me Deen TNE lg cepa ; . oe a SCL, Pan OPAC - ‘ oo , ; he OV cee rade Fate . Delius, A025: . 752 i Dear bo. Cochran; _ . request Lor ‘yuling Gated January eg, > bachelor quurvers Supplied vo voor aCGS you present must fore) Considered passers, ifee PoSSS. Ek o 2A. The are as Lollouws 1 S . tT. - 54 vere “ Arn oot treat + oa. wen on biadeox a 2 ee Weare wis COE GY GG we Ur UCR DUNO as Coverssens, five 7 1S. CLbiZ cuployees of this company work 2a2LL tinic O02 &@ Joint sustrei rant wUnived States Goverment installation Bi Auotralia. -Tne installation is in a resote location approxiniately 1,009 ingles fox the nearest city of ny sive, except Lor alice nant Wish bas 4. populavion of oDDz rosins tcl 93000. Alice Springs LG wdles Leon the v mo installcvion and is the ont sown within commu ving “Cintanea, , ac talc tion cperetes on a 2henour bashes ane we ovadloble for ausy at any time, it is neces: aay bi 2 GSSiyned to then oy the U.S. Covetiuacnt. Q&S Gzssien i ‘ 4 BON 2S 04 tha installation and BALYLCA GLE os GPS Goohvna. g ; nouses in Alice Springs. Tac nued sox avadlabili vy OL elie enuployees. is such that all quarters, inci; 2 ee a Pant caployoudg Wey oye rad wy LY rererey Wt rat ies VW Wawss Lor mars eipleyees, would da on tha base oxcept iay secu Dae Way ‘ Seyulavions do noy POBALE fiaily aewergs of the cory many ls en Lovee: ib wo insvuilatvion. Ibis a conaition of enployzicn 6 tos capleyuas : i a Live on dive in ote moors assimed to thon. thoy are givea no choice OB 1a ysticsvecs APUONO, cselestion ol TS “SENS, Hey hoe olect a Casn aLLowincoe an licu oc « ang ars not cllowed vO deuce, : purchaso or ouild houses OF Apis vans : wneiz OW Re . . an & OL OF the Interaal Revenue Code provides baie. ual WLES OicLedud by law, exvoss incoiae means all incowa @: "On WAtOVOr ouiem Source Curived, inclad: Ag Compensation for services. HW°53216 Decld:32358065 “Page 4d a
rh Wiha pfose income of an employee the veluo vo! apoyer for the convenien A se ty onG6, fore} Lee Comanee AGG 220: ert “ 2 a oe aod Go ing susnionee re) moi Oe enployen, , wae ondir oe. on thse 3 CUSLAaGSS pretises oz . Section 129 of she Code provides, in pertinent part, that, thors ol, vis S cuployer™ ‘as a conditien, or en M3Ge - ‘ . oa . ; . Seovion WelLS-2(b) of tue Lancome Pas Regulations provides shat tic Value of Lodging zu walgshed to an enployes by the caployor shall we on. aa an cluded from the expicyee's G2coss incone az tarea © veses ara nee: . 1 3 Feo ee eS : i a. . The Lodging is Sacoished - on the business praai isos of ase cuphoyer 2. The locsiag is furnisied d Lor the conveniences of the GhOLOyev, O06 7 ; 4 * : > i Se The ea rCe a5 required vo accept such lodzinz is ‘ & condition of nis anployzent. _. ; Based solely oa the representations nado, WE concluce that these threo tests are note Copare Example (7) of section 1. UGG) of She: Regulations. ‘@herelozc, ths value of tas lodging fumishcd to your Gnployces elthcr inthe instaliation barracks or in the city m. ds excludadic from the gross acome of such cnploy COS6 DGwESS - De - ‘ ‘Sincoroly yours, Chiog » Corporation Tax. Brauch : awe ‘ga016 “Doora: 35358065 “Page 5°
OGC 71-0143 COLLINS Ee oo . . , a cS . OF saad OGC Subj: FEDERAL TAXk., ‘Dallas, Texas 75207 Area Code 214 235.951) Cable: COLINRAD DA January 22, 197] Commissioner of Internal Revenue Attention: Mr. Erskine H. Hatfield washington, D. C. 20224 © . Dear Mr, Hatfield: 1. Under a contract between this company and. the United ‘States Government, five U.S. citizen employees of this company work ful] time on a joint Australian-United States Government installation in Austratia. The installation is in a remote location approximately 1,000 miles fron the nearest city of any size, excent for Alice Springs, which has a popu=— lation of approximately 9,000. Alice Springs is 15 miles from the instal- ' lation and is the only town within commuting distance. 2. Because the installation Operates on a 24-hour basis and these employees must be available for duty at any time, it is necessary that they live in quarters assigned to them by the U. S, Government. Bachelors are assigned rooms in BOQ's on the installation and married employees are ‘assigned specific houses in Alice Springs. The need for inmediate avail- i employees is such that all quarters, including those for _ Married employees, would be on the base except that Security reculations do not permit family members uf the company's employees to live on the installation. It is a condition of employment that employees live in the ' quarters assigned to them. They are given no choice in selection of quarters, may not elect a cash allowance in liey of quarters, and are not allowed to lease, purchase or build houses or apartments on their own. pol oe — — ys ct < ° > m& ~— ~ - The installation is a .joint Australian-United States facility. The bachelor Quarters were constructed by the United States Government and the houses by the Australian Government for occupancy by both American and Australian employees. Bachelor quarters on the base and the houses jn Alice Springs are rent free to the company's American employees, utilities and furnishings included. In accordance with Australian Government policy, the company's Australian employees are Charged $A17.50 per week for the ~ houses including furnishings and utilities, which houses are comparable to those supplied rent free to American employees. Similar houses in the town rent for about $A35.00 per week not including furnishings and utilities. '  . We are advised that the Australian Government Subsidy to Australians -of Po about one-half of the rental value, like the U. S. Government's provision oO oe of free housing, is paid in recognition of the housing shortage and the _ requirement to live in. assigned housing. ‘It is our understanding that the Gey “iw 53216 ‘DocTd:32358065' Page 6 |
. » . , ars . : aor, ra : we : . . Ag | oo ; COLLINS RADIO COMPAN: Mr. Hatfield Eg January 22, 1977 ee nustralian Tax Department does. not require Australian employees to report as income the difference between the value of quarters and the rent paid, ; i although Australian income tax law provides that the value of lodging a ee | Supplied by an enployer is taxable income, —s.: a _ 4. We request your ruling as to whether the value of the bachelor quarters on base or houses jn town supplied to our American employees under these circumstances must be considered income for tax purposes. We understand that the Australian Government has advised that for purposes of Australian taxation of American employees, it would treat the value of the quarters in the same manner as the United States Internal Revenue a : _, Service does. oO 7 8, If your tentative ruling is that the value of quarters is tax- able income, we requ uest a conference prior to the issuance of the final ruling. . Oo Se , . Yours very truly, | wal ¢ ( - WY Coden W. P. Cochran ; Manager, Tax Department © MPC: Im, | cc: J. Morrison, ur.¥ BE. C. Christerson . MW-33216 “Docld:32358065' “Page \7. |
7 . 7 . ® . . | . @ | . 7 + 7 BIF-004-07-1482 os COPY. ¢C2: TOTAL PAGES 002 ~ Coumissioner of Internal Revenue Attn: Mr. Erskine H. Hatfield Wasnington, 5. C. 20226 1. .Tais Company is a Subcontractor under a prime contract with tne United States Government and has about thirty-seven enployees of the Company working on a Joint Australian/U.S. Government installation in Australia. The instaliation is in a remote location approximately 1,060 miles from the nearest city of any size. The largest town nearer to the installation is Alice Springs, which has a population of approxie -Mately 9,000. Alice Springs is 15 miles from the installation and is the only town within commuting distance. ; 2. Because the installation operates on a 24-hour basis and enployees must be available for duty at any time, the Company's contract requires that enployees live in quarters assigned to them by the U. S. Government. Bachelors are assigned rooms in B0Q's on tne installation and married employees are assigned specific houses in Alice Springs. The need for — immediate availability of al} employees is such that all quarters includ- ing those for married employees, would be on the base except tinat security regulations do not permit family menbers to live on the installation. It — “is a condition of enployment that euployees live in the quarters assigned. . “0 them, They are given no choice in selection of the quarters, may not elect. a cash allowance in lieu of Quarters, and are not ailowed to lease, purchase or build houses or apartments on their own. 3. The installation is a joint U.S.-Australian facility. The bacheior’ Guarcers were constructed by the U.S. Government and the houses by tne. Australian Government, for occupancy by both American and Australian enployees. Bacnelor quarters on the base are rent free to both Australian and Auerican euployees and the houses are rent free to Anerican enployees, .-kn accordance with Australian Governnent policy Australian employees are Charged rent of $17.50 per week for tne houses. Similar nouses in the town rent for about $35 per week. The Australian Government subsidy to Australians of about one-half the rental value, like the U.S. Government's provision of free nousing, is paid in recognition of the housing shortage and the requirement to live in assigned nousing. The Australian tax ; vepartient does not require Australian employees to report as income the .— ae difference between the value of quarters and the rent paid, although Australian income tax law provides that the value of lodging supplied by an exployer is taxable income. Se . * meena ame, ties reise y 4 3 A ¢ eu SYSTEMS ° ONG ePace PARK * AEOONOCO BEACH ¢ Cauironnia, 80878 + ac... “HW 53216 Docld:32358065° Page 8
eee . . “. <e . so . Lo . oe . BIF-004-07-1482 | | | 4. We request. your ruling as to whether the value of the bacneior _ Quarters on base or houses in-town supplied to our employees under _ these Circuilstances must be considered income for tax purposes. The — Australian Goverrment has advised that for purposes of Australian taxa- — : | tion of American employees, it will treat the value of the quarters in. . the. same manner as the United States Internal Revenue Service does. 5. If the tentative ruling is that the value of quarters is taxable, we respectfully request a conference prior to issuance of a final ruling. wee ‘Very truly yours. ; ; . Robert B. Corpening i ae General Counsel} . 7 TRW Systems Group ‘ ‘ | | if | “¢ t . t “HW .'53216  DocTd:32358065. Page 9-
Sp [lo T, \Y eLcreEctrRoSsyY: EMS, ING. . oo : GARLAND OIVISION AREA CODE 214 BROAOWAY 6.7091 15 December 1970 4-60000W/0L-58 - Commissioner of Internal Revenue Washington, D. C. 20224 Attn: Mr. Erskine H. Hatfield. onl Subj: Request for Ruling . | Gentlemen: my LIV Electrosystems, Inc. is a subcontractor under a prime contract with ; an ' the U. S. Government and has approximately se enty-five (75) employees ‘working at a joint United States and Australian installation in Australia. The installation is in a remote location approximately 1,000 miles from the nearest city of any size. The largest town nearer to the installation _{48 Alice Springs, which has a population of approximately 9,000. Alice Springs is 15 miles from the installation and is the only town within commuting distance. , ’ _ Because the installation Operates on a 24-hour basis, the U. S. Government requires all prime contractors and their subcontractors’ employees to be available. for duty at any time and that employees live in quarters assigned _ to them by the U. S. Government. Bachelors are assigned rooms in BOQ's on | the installation and married employees are assigned specific houses in ; Alice Springs. The need for immediate availability of all employees is i such that all quarters, including those for married employecs, would be on , the base except that security regulations do not permit family members to live on the installation. It is a condition of employment that employees live in the quarters assigned to them. They are given no choice. in selection of the quarters, may not elect a cash allowance in lieu of quarters, and are not allowed to lease, purchase or build houses or aparte- - ments on their own. ; a The installation is a joint U. S. - Australian facility. The bachelor quarters were constructed by the U. S. Government and the houses by the Australian Government, for Occupancy by both American and Australian Be a ; employees. Bachelor quarters on the base are rent free to both Australian ; and American employees and the houses are rent free to American employees. ; pe . In accordance with Australian Government policy Australian employees are oe So , ; charged rent of $17.50 per week for the houses. Similar houses in the town - a : rent for about $35 per week. The Australian Covernment subsidy to Australians co 4: @f about one-half the rental value, like the U. S. Government's provision of ~ — ' free. housing, is paid in recognition of the housing shortage and the require- . went to live in assigned housing. The Australian. tax department does not . ts Patna Lae Hae ~ ” HW 53216 “Doctd: 32358065 Page 10 ° co Cot 5
ee nae | S Oo @ . i. cage. ; . 1’ 4-60000W/OL-58 ; 15 December 1970 require Australian employees to report as income the difference between the ’ . 7 value of quarters and the rent paid, although Australian income tax law : provides that the value of lodging supplied by an employer is taxable income. We request your ruling as to whether the value of the bachelor quarters on ' base or houses in town supplied to our employees under these circumstances must be considered income for tax purposes. . The Australian Government. has advised that for purposes of Australian taxation of American employees, it will treat the value of the quarters in the same manner as the United States . ' Internal Revenue Service does. , —— If your tentative ruling is that the value of quarters is taxable income, we request: a conference prior to issuance of a final ruling. — ; : a ; Very truly yours, RK. L. Lewis . Vice President, Administration en ee eee RLL/g ee « HW 53216 \DocTd:32358065 Page 11° --~
Department of the Treasury | internal Revere Sorvice | oe Washington, He 20224 ¢ Was ES . | ; : Date: — in-reply refer to: Vj s ‘ys —— | Degeaber 29, 1970 T:IsC _ "> Mr. Re Le Levis “LIV Flectrozysteas, Ino. P. 0. Box 6118 .. metas, ‘Texas "75222 ° 7 Ts ‘Dear Kr. Lewlos . This Is to let you know that we have received your tng becesber 35, 1970, oo 4 ” We will send you a reply as soon as + possible. . i . Very tly yours, | ‘ye a Sch wae rh ard : x Ht. Leds poecelghan in .- : 20% coapaaatien ‘tae Besa e 7 és vente oh Tat B ronth ( oo a - . — , FORM 37MA (REV. 2-67) . — Vhs DS omy Guess HW .53216 Docld:32358065. ‘Page 12
oe - yay VE Gone iNaraA) 3 2 3S / 5 (7 : . ee a a: ee ot een een ens ment ere ola | ss as | ; | a Pai 44 oa a + Coens ws yo . ' a al fig et a - NOTE ATTACHED TO OCC 71-0143. HW 93216 DocId:32358065 “Page 13° *