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petitioners' lounges or in the gambling area, supplying gamblers
with free alcohol 24 hours a day. The question, therefore, is
whether the serving of alcohol is the serving of food. We do not
believe it is. We construe the word "food", for this purpose, to
mean "Material, usu. of plant or animal origin, containing or
consisting of essential body nutrients, as carbohydrates, fats,
proteins, vitamins, or minerals, taken in and assimilated by an
organism to maintain growth and life." Webster's II New
Riverside University Dictionary 494 (1994). Alcohol is simply
not within this definition. Indeed, in the case of bartenders,
they are treated differently from the other "culinary workers"
under the labor agreement that applies thereto. We conclude that
petitioners' cocktail servers, bartenders, and barbacks are not
food service employees, and, hence, that they are not entitled to
exclude their meals on that account.
7. Promote Morale or Goodwill
An employer furnishes a meal to an employee for a
compensatory business reason if the employer furnishes the meal
intending to promote the employee's morale or goodwill. Sec.
1.119-1(a)(2)(iii), Income Tax Regs.
Petitioners furnish the meals to their employees to retain
them as employees. Accordingly, petitioners furnish the meals to
promote employee morale and goodwill, and, hence, petitioners
have a compensatory business reason in furnishing the meals.
Absent a substantial noncompensatory business reason, meals
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