Bernardus A. P. Dobbe and Klazina W. Dobbe - Page 22




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               Generally, meal expenditures are treated as personal                   
          expenses and are not deductible for Federal income tax purposes.            
          See sec. 262; Rhoads v. Commissioner, T.C. Memo. 1987-335;                  
          Fenstermaker v. Commissioner, T.C. Memo. 1978-210; sec. 1.262-              
          1(a) and (b)(5), Income Tax Regs.  Only those meal expenditures             
          that satisfy the requirements for deductibility under section               
          162(a) may be deducted as business expenses.                                
               Holland America has failed to prove that its reimbursement             
          of Mr. and Mrs. Dobbe’s grocery expenses, covering a 5-year                 
          period, was anything more than the payment of a personal expense            
          of its shareholders-officers.  Although Holland America contended           
          that the reimbursement met the requirements of section 162(a), it           
          did not offer any credible evidence to show that the                        
          reimbursement was ordinary or necessary under the circumstances             
          involved here.  Mr. and Mrs. Dobbe lived on the farm.  They                 
          bought groceries and cooked their meals in their own home.                  
          Although Mr. and Mrs. Dobbe were involved in the day-to-day                 
          operation of the farm and may have eaten meals occasionally while           
          addressing issues on the farm, they did so for their own                    
          convenience.  The mere possibility that an emergency may arise on           
          the farm does not convert a personal expense into a business                
          expense.  See Rhoads v. Commissioner, supra.                                
               Holland America had other employees in addition to Mr. and             
          Mrs. Dobbe, yet the corporate policy was limited solely to Mr.              






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