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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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Last modified: May 25, 2011