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meeting.6 Accordingly, petitioner is only entitled to deduct 80
percent of her meals expenses.
Petitioner argues that pursuant to IRS Publication No. 17
for 1991, she is entitled to a 100-percent deduction for her
meals expenses. At trial, petitioner purported to quote a
section of that publication. However, we were unable to locate
in that publication the section to which petitioner referred at
trial. Rather, IRS Publication No. 17 for 1991 refers to IRS
Publication No. 463 for 1991 for a list of expenses which are
exceptions to the 80-percent limitation of section 274(n). In
our examination of IRS Publication No. 463 for 1991, we located
the following paragraph which is identical, with the exception of
the last sentence, to the section which petitioner read at trial:
TRADE ASSOCIATION MEETINGS. You can deduct expenses
that are directly related to and necessary for
attending business meetings or conventions of certain
exempt organizations. These organizations include
business leagues, chambers of commerce, real estate
boards, trade associations, and professional
associations. The expenses of your attendance must be
related to your active trade or business. These
expenses are subject to the 80-percent limit on
entertainment expenses. (Emphasis added.)
Obviously, petitioner failed to read the last sentence. Clearly,
IRS Publication No. 463 does not authorize a 100-percent
6 Sec. 274(n)(2) includes an exception for certain expenses
that are described in sec. 274(e)(2), (3), (4), (7), (8), and
(9). Sec. 274(e)(6), which refers to expenses related and
necessary to attendance at a business meeting or convention of
certain organizations, is not included as an exception.
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