- 15 - matching inclusion in the income of the recipient and generally to prevent the deduction of personal expenditures under the guise of business expenses.” World Wide Agency, Inc. v. Commissioner, T.C. Memo. 1981-419; see also H. Rept. 1447, 87th Cong., 2d Sess. (1962), 1962-3 C.B. 405, 423. Since section 102(c)(1) precludes treatment of gifts to employees as tax-free gratuities, the principle of matching income inclusion and deduction will be protected in situations such as that now before the Court. We therefore hold that the gift nut baskets presented to employees of R&J are not gifts within the meaning of section 274(b) and that deduction of amounts expended to purchase the baskets is not subject to the $25 limitation. Hence, a deduction of $61 is allowed for each basket given to those stipulated as employees. 3. Christmas Bonuses With respect to the $100 bills given to employees as Christmas bonuses, petitioners rely primarily on the argument that the full $4,200 is deductible under section 162(a)(1) because it represents compensation paid to those employees. Alternatively, if the bonuses are characterized as gifts, petitioners aver that they are fully deductible for the same reasons as were discussed above in connection with the nut baskets.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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