- 3 - 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.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011