Anne R. Dugan - Page 3

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          common, as Dr. Zimmerman referred a number of patients to                   
          petitioner.                                                                 
               During 1994, petitioner and Dr. Zimmerman often met at                 
          lunchtime and shared meals.  At their lunch meetings, petitioner            
          and Dr. Zimmerman discussed treatment of their patients and                 
          details of office administration and operations.  Petitioner also           
          met with Dr. Zimmerman at times when they did not share a meal,             
          but lunchtime was often the best opportunity to meet.                       
               Petitioner and Dr. Zimmerman alternated paying for their               
          meals together.  Each week, petitioner paid for one to three                
          meals with Dr. Zimmerman.                                                   
               On her Federal income tax return for the taxable year 1994,            
          petitioner reported expenses attributable to meals taken with Dr.           
          Zimmerman totaling $900.  After application of the 50-percent               
          limitation for meals and entertainment pursuant to section                  
          274(n)(1), these expenses gave rise to a claimed deduction of               
          $450, which respondent disallowed as not being ordinary and                 
          necessary expenses for petitioner's trade or business.                      
                                       OPINION                                        
               Section 262(a) generally disallows the deduction of                    
          personal, living, or family expenses.  Except as permitted under            
          sections 162, 212, or 217, the costs of a taxpayer's meals not              
          incurred in traveling away from home are nondeductible personal             
          expenses.  Sec. 1.262-1(b)(5), Income Tax Regs.                             





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