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clearly linked to her production of income. They met at
lunchtime because that was the most convenient and feasible time
to meet. Their business relationship was well established and
did not require "social lubrication", at least not as often as
petitioner and Dr. Zimmerman dined together. Indeed, the
frequency of their lunches together and the reciprocal nature of
their meal arrangement belie the existence of any business
purpose for the meals.
Petitioner has stipulated that she and Dr. Zimmerman
alternated paying for the meals. In substance, then, each was
bearing only the expense of her individual meals. If taxpayers
were permitted to deduct meal expenses in such circumstances
then, as this Court has observed, "only the unimaginative would
dine at their own expense." Moss v. Commissioner, 80 T.C. at
1081.
Accordingly, we sustain respondent's determination. To
reflect the foregoing and concessions by the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011