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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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