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(Vol. 4) at 24-25, we do not find this statement to be
disharmonious with our reading of the statutory text. Although
we need not and do not pass on the breadth of this statement, one
reasonable interpretation is that the entire cost of a
section 119 meal is not deductible when the meal is outside of
the de minimis fringe benefit exception of section 132(e).
We find further support for our reading in the reason for
section 274(n)(1). The Congress included section 274(n)(1) in
the Tax Reform Act of 1986, Pub. L. 99-514, sec. 142(b),
100 Stat. 2085, 2118, primarily to address their concern that the
then-present law unfairly allowed high-income taxpayers to
structure their business affairs in a way that generated
deductions for personal expenses such as meals. As stated by the
committees, with respect to the need for a change in the
then-present law,
Since the 1960's, the Congress has sought to
address various aspects of deductions for meals,
entertainment, and travel expenses that the Congress
and the public have viewed as unfairly benefiting those
taxpayers who were able to take advantage of the tax
benefit of deductibility. In his 1961 Tax Message,
President Kennedy reported that “too many firms and
individuals have devised means of deducting too many
personal living expenses as business expenses, thereby
charging a large part of their cost to the Federal
Government.” He stated: “This is a matter of national
concern, affecting not only our public revenues, our
sense of fairness, and our respect for the tax system,
but our moral and business practices as well.”
The committee shares these concerns, and believes
that these concerns are not addressed adequately by
present law. * * *
The committee believes that present law, by not
focusing sufficiently on the personal-consumption
element of deductible meal and entertainment expenses,
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