Anne R. Dugan - Page 6

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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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