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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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