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procedures to compute a deduction for “meals and incidental
expenses”. Respondent concludes from the quoted language that
the revenue procedures apply only when both meals and incidental
expenses are incurred, or when meals alone are incurred. We
disagree with respondent’s conclusion. We do not see how the
language “meals and incidental expenses” could be construed to
apply when only meals are incurred but not when only incidental
expenses are incurred. We read the revenue procedures to apply
to three distinct situations; i.e., (1) where a traveling
employee pays only for meals, (2) where a traveling employee pays
for both meals and incidental expenses, and (3) where a traveling
employee pays only for incidental expenses.
We are mindful that the relevant provision of the revenue
procedures is headed “Optional method for meals only deduction.”
E.g., sec. 4.03 of Rev. Proc. 96-28, 1996-1 C.B. 686. However,
we do not believe that this heading is dispositive as to the
breadth of the related text. That text, when read in the context
of the related revenue procedure as a whole, clarifies that the
provision was intended to apply to costs for both meals and
incidental expenses. The revenue procedures allow a taxpayer to
compute a deduction for business meals and incidental expenses in
accordance with the rules of the travel regulations set forth in
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