- 81 -
All of these percentages are less than even 50 percent.
Thus, each of substantially all of petitioners' employees may not
exclude the meals from their gross incomes, and, hence, all
employees may not exclude the meals. It follows that petitioners
may deduct only 80 percent of their expenses with respect to the
meals, and we so hold. We have considered all arguments made by
petitioners for a contrary holding and, to the extent not
discussed above, find them to be irrelevant or without merit.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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