[2] The Commissioner of Internal Revenue assessed a tax deficiency after determining the taxpayers (the Gotchers) had realized income of $1,372.30 from the trip.

[4] At issue was whether the cost of the trip was taxable income to Mr. and Mrs. Gotcher under Section 61 of the Internal Revenue Code.

The court referenced Section 119 of the Internal Revenue Code, which excludes from the gross income of an employee "the value of meals and lodging furnished to him for the convenience of the employer," as guidance for the decision.

[8] Her attendance was primarily to his personal benefit, and there was no evidence on the record that her presence served a bona fide business purpose.

[8] For income tax purposes, the case is notable for the articulation of the "primary benefit to the provider doctrine."

A business only pays employees for the benefit of labor which will provide greater returns than expenses and contract consideration is only furnished to receive a preferred gain.

The statement, "a single trip by a wife with her husband to Europe has been specifically rejected as not being the exceptional type of case justifying a deduction,"[8] has insidious ramifications for tax (and social) consequences of women (or men) that perform legitimate work on behalf of their partner or spouse.

[citation needed] Perhaps the concurring opinion articulates even more clearly the popular belief about women's informal work performed on behalf of their partner’s business.