"The tax preparation services provided by Taxpayer for the benefit of its employees working in foreign countries are includable in the employees' gross income. [2] The amount includable in the employees' gross income is the fair market value of the tax preparation services. [3] The fair market value of the tax preparation services constitutes wages for FICA tax purposes. [4] The fair market value of the tax preparation services constitutes wages for purposes of FITW, unless Taxpayer had a reasonable belief that such value would be excludable from the employees' gross income under Section 911 or Taxpayer was required by the law of a foreign country to withhold income taxes on such value."

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