Sherri A. Mulne a.k.a. Sherri A. Shannon - Page 9

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            connection with sales representative meetings between 2 to 7                               
            times per month.  Petitioner credibly testified that her meals                             
            expenses were not reimbursable by Pacific Bell.  Mr. Moreno did                            
            not convince us otherwise.  Ms. Groves' letter did not mention                             
            any Pacific Bell policy regarding reimbursement for meals with                             
            other employees.  Accordingly, we hold that petitioner's meals                             
            expenses were not reimbursable by Pacific Bell.                                            
                  To substantiate her meals expenses, petitioner presented a                           
            detailed calendar for 1991 in which she recorded the date,                                 
            amount, place, and business purpose of the meals expenses.  In                             
            addition, petitioner credibly testified that the meals expenses                            
            were incurred to motivate her sales representatives or incurred                            
            in connection with meetings to discuss accounts or other work-                             
            related problems with her sales representatives.  Based on                                 
            petitioner's calendar and testimony, we conclude that she                                  
            incurred meals expenses for lunch and dinner of $1,843.20 and for                          
            sales representative meetings of $569.  Accordingly, petitioner                            
            is entitled to a meals expense deduction based on those amounts,                           
            subject to the 80-percent limitation imposed by section 274(n).                            
                  c.  Contest Prizes.  In 1991, Pacific Bell held a 6-month                            
            contest to motivate the sales representatives to maximize                                  
            revenue.  Winners of the contest received awards totaling $1,000.                          
            The sales manager was required to pay the bonus and was entitled                           
            to reimbursement from Pacific Bell.  Four of petitioner's sales                            





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