Regarding the non-taxability of imputed income from the performance of household services under U . S . federal income tax law, Professor Andrews wrote : " . . . . it is commonly considered that difficulties of valuation would interpose an insuperable obstacle to any direct inclusion of such items in taxable income . " Commentators Burke and Friel have written : " The exclusion is rather a matter of administrative practice, but no less firmly established for that reason ."
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