Commissioner v. Kowalski, 434 U.S. 77 (1977), is a decision of the United States Supreme Court relating to taxation of meals furnished by an employer. In this case, the Court interpreted Internal Revenue Code §119(a)-(b)(4) and (d) and Treas. Reg. §1.119-1. Most notably, the Court held that: * §119 was intended to exclude meals received "in kind," and so does not exclude cash reimbursements for meals like the one in question.