Norman E. Duquette, Inc. - Page 30




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          IV.  Business Meals                                                         
               A.  Introduction                                                       
               On the 1994 tax return, under the heading other deductions,            
          petitioner deducted $16,070.60 for “Business Meals” (business               
          meals).  On brief, petitioner concedes a portion of the                     
          adjustment for business meals, arguing for a deduction of                   
          $14,777, divided as follows:                                                
                    Per diems - Aline Duquette    $6,440                              
                    Per diems - Norman Duquette   10,010                              
                    Business meals with clients   1,711                               
                    Board of directors meetings       310                             
                           Total                  18,471                              
                    Deductible business meals (80 percent)6 $14,777                   
               We may also dispose of this item without much discussion.              
          Respondent argues lack of substantiation, failure to report                 
          reimbursements, and duplication of certain expenses.  Petitioner            
          supports the deduction with the analyses and other stipulated               
          documents.  For the same reason as set forth supra, in                      
          section III, we find that all reimbursements were included in               
          gross income.                                                               
               B.  Per Diems – Aline Duquette                                         
               We allow no deduction with respect to the $6,440 claimed as            
          business meals for “Per diems – Aline Duquette”.  Petitioner                
          argues that it paid Aline per diem of $35 a day for 184 days                


               6  With exceptions not here pertinent, sec. 274(n)(1)                  
          provides that any deduction for food or beverages shall not                 
          exceed 80 percent of such expense.                                          





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