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filed a consolidated Federal income tax return. CHC’s affiliated
group in its 1987 taxable year included: (1) Mare-Bear, Inc.,
doing business as Stardust Hotel & Casino (Stardust) and
(2) Sam-Will, Inc., doing business as Fremont Hotel & Casino
(Fremont). CHC sometimes did business as Sam’s Town Hotel
& Gambling Hall (Sam’s Town).
For its taxable year ended June 30, 1989 (the 1988 taxable
year), Boyd was the common parent of an affiliated group of
corporations that filed a consolidated Federal income tax return.
Boyd's affiliated group in its 1988 taxable year included: (1)
CHC, which sometimes did business as Sam’s Town, (2) Mare-Bear,
Inc., doing business as Stardust, and (3) Sam-Will, Inc., doing
business as Fremont.
At all times relevant herein, CHC, Stardust, Fremont, and
Sam's Town (collectively referred to as the Properties) were
located in Las Vegas, Nevada. Each of the Properties was a
resort complex that had casino, hotel, and restaurant facilities.
Some of the Properties had convention or amusement facilities.
Each of the Properties had an employee cafeteria that was located
on its premises. The cafeterias (Cafeterias) were separate from
the public restaurants that were located on the Properties. The
Cafeterias were used by petitioners to serve hot meals, cold
foods, and snacks (collectively referred to as the meals) to only
their employees.
Petitioners provided the meals to all of their on-duty
employees, except for a small group of individuals who were
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