True, mainly because the benefit was probably provided pre-tax or perhaps even included as a perk that would exclude it from being taxed.
By most statutes, a discount does not equal a gift.
According to the US Dept of Labor:
Gifts
What Is a Gift? - 5 C.F.R. § 2635.203(b) and (c)
A gift is anything that has monetary value that you obtain for less than “market value.” The gift might be tangible or intangible. A gift may include, but is not limited to, a gratuity, favor, discount, cash, gift certificate, gift card, entertainment, hospitality, loan, forbearance, or other item having monetary value. It also applies to services, training, transportation, travel, lodging, and meals. See 5 C.F.R. § 2635.203(b).
Exclusions: Some Things Are Not Gifts
Some items are excluded from the definition of gift, and you may accept them pursuant to certain specific regulatory exclusions.
Discounts and similar benefits that are offered to the public, other groups that you belong to, or to all Government employees.
- Modest items of food and non-alcoholic refreshments such as soft drinks, coffee, and donuts, not offered as part of a meal.
- Greeting cards and items of little intrinsic value such as plaques, certificates, or trophies, which are intended primarily for presentation.
- Prizes in contests open to the general public.
- Commercial discounts available to the general public or to all Government employees.
- Commercial loans, pensions, and similar benefits on terms available to the general public.
- Anything for which you pay fair market value.
- Anything that is paid for by the Government.
- Free attendance provided by the sponsor of an event to which you have been assigned to present information on behalf of the agency.
This exception includes favorable rates offered to all Federal employees even when you are off duty. It also includes favorable rates and commercial discounts offered to members of a group or class in which membership is unrelated to Federal employment.
As I mentioned before, MANY companies (theme parks, hotels, phone companies, etc.) already offer such discounts to government, military, first reponders, etc. It's not a violation.
Hotels, rental car companies, Amtrak. etc., offer discounts to government employees. It is NOT a gift under the IRC. Disney used to on tickets back in the 1990s. And rooms, if I remember.
I'm a retired government employee. I never had to claim the discounts I received on hotel rooms for official government travel as unearned income on my 1040.