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