Assessing Internal Revenue Code Section 132 After Twenty Years

Authors

Wayne M. Gazur, University of Colorado Law SchoolFollow

Document Type

Article

Publication

Virginia Tax Review

Year

2006

Citation Information

Wayne M. Gazur, Assessing Internal Revenue Code Section 132 After Twenty Years, 25 Va. Tax. Rev. 977 (2006), available at https://scholar.law.colorado.edu/faculty-articles/746.

Abstract

In 1984, Congress enacted Internal Revenue Code section 132 to bring more certainty to the taxation of employee fringe benefits. This article examines the impact of the legislation from the standpoint of administrative pronouncements and taxpayer litigation. The article concludes that section 132 has produced little litigation, but primarily because it has played the role of increasing exclusions. It remains unclear whether section 132 has also contained the growth of new forms of nonstatutory fringe benefits.

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