- 45 - Petitioners do not limit an employee's activities when he or she travels to or from work in uniform. The employees who travel from work in uniforms typically change their uniforms before going out on personal business after work, but some uniformed employees have gone out after work in uniform and eaten at a competitor's restaurant. Petitioners make no attempt to account for the actual cost of the meals that are served at the Cafeterias. In the case of Stardust, petitioners expense a flat charge per month, regardless of the number of meals served, based on an estimate of food costs that was made before the subject years. For the other Properties, petitioners multiply a fixed amount (ranging from $1.75 to $2) by the number of full-time employees on the rolls of each department in each month. In accordance with this expending policy, petitioners ascertained that their direct costs for the Cafeterias for the 1987 and 1988 taxable years were as follows: 1987 1988 CHC $459,205 $616,483 Fremont 372,705 388,546 Sam's Town 741,366 811,628 Stardust 1,215,638 2,030,010 Total 2,788,914 3,846,667 Petitioners deducted all of these costs, with the exception of the following amounts for 1987: CHC $68,044 Fremont 45,781 Sam's Town 98,012 Stardust 145,978 Total 357,815Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
Last modified: May 25, 2011