In the last pay period of 2019, Tampa Bay Corporation paid an additional $150 to all its full- time employees in recognition of the holiday. Tampa Bay Corporation Corporation would like to know if the $150 payment per employee is (1) taxable income to the employee and/or (2) tax deductible to the corporation.

A partial list ofresearchsourcesincludes:

• Secs.74(c),102, 132(c),and 274(6)
• Reg.Sec. 1. 132-6(e)(l)
• Hallmark Cards,Inc.v.U.S.,9 AFTR 2d391,62-1 USTC, 9162(DC-Mo,1961).
• Rev. Rul. 59-58, 1959-1 CB 17.
• All these sources must be citated in your answer. Your submission should be in the form of a tax research memo (i.e., Facts, Issue, Applicable Law, Analysis, Conclusion sections).
• All TRQ submissions must be as a PDF and one to two pages in length, single-spaced or approximately 500 to 750 words.