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that day. Petitioner presented two stubs to substantiate meals
on July 7, each in the amount of $193.50. Neither stub has the
name of the restaurant imprinted on it. The stubs are of the
same style, but with different serial numbers. Petitioner’s
diary shows a $193.50 dinner for January 31 and another one for
May 8; there are different stubs to “substantiate” each of these
meals. The diary does not show any other meals costing $193.50.
Petitioner’s diary shows that petitioner took people to
meals at North Shore Steak House on four occasions in 1987--all
were dinners during the 16-week period from September 4 through
December 23. Petitioner presented stubs to substantiate each of
these four dinners. None of these four stubs has a restaurant’s
name imprinted on it. Each of these four stubs is in a style
different from the other three.
There are numerous instances in which a single restaurant is
represented by stubs of different styles. There are numerous
instances in which stubs of a single style with close receipt
numbers are represented as coming from different restaurants.
The Crabtree Dealerships did not have a formal reimbursement
policy for meals and entertainment expenses incurred by an
employee. The Crabtree Dealerships’ informal policy was to
reimburse an employee for meals and entertainment expenses if the
employee was asked to incur the expense, but not otherwise.
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Last modified: May 25, 2011