Anne R. Dugan - Page 5

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               time was the most convenient time at which to meet.  We                
               are also convinced that the partnership benefited from                 
               the exchange of information and ideas that occurred.                   
                    But this does not make his lunch deductible any                   
               more than riding to work together each morning to                      
               discuss partnership affairs would make his share of the                
               commuting costs deductible. * * * [Moss v.                             
               Commissioner, supra at 1080-1081.]                                     
               In affirming this Court's decision in Moss v. Commissioner,            
          supra, the U.S. Court of Appeals for the Seventh Circuit focused            
          on the lack of a business objective for the meals, distinguishing           
          meals with "outsiders", such as clients or customers, from meals            
          with coworkers:                                                             
               [Coworkers] know each other well already; they don't                   
               need the social lubrication that a meal with an                        
               outsider provides--at least don't need it daily.                       
                         *    *    *    *    *    *    *                              
               * * * the meal itself was not an organic part of the                   
               meeting, * * * where the business objective, to be                     
               fully achieved, required sharing a meal.  [Moss v.                     
               Commissioner, 758 F.2d at 213-214.]                                    
               Similarly, in Hankenson v. Commissioner, T.C. Memo. 1984-              
          200, this Court held that expenses of meals incurred by a                   
          physician in the course of frequent lunchtime meetings which he             
          hosted for nurses and medical colleagues constituted                        
          nondeductible personal expenses, because of the absence of a                
          clear nexus between the expenses and the taxpayer's production of           
          income.                                                                     
               In the instant case, sharing a meal with Dr. Zimmerman was             
          not integral to petitioner's business objectives and has not been           




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