- 20 - supra, applies only where the reimbursement includes an amount for lodging expense, and that Rev. Rul. 84-164, supra, applies to situations involving meals and incidental expenses, but not lodging. However, Rev. Rul. 80-62, supra, does not require a lodging expense and by its specific terms, Rev. Rul. 84-164, supra, limits its applicability to allowances for meals only and deems $14 as the amount substantiated. In analyzing the expenses which the revenue rulings are designed to cover, a logical disconnect surfaces. Under a plain reading of the two rulings, combined with our decision in Murphy v. Commissioner, supra, the difference between the amount that can be deemed substantiated under each ruling, $30, can be attributed solely to incidental expenses. However, Rev. Rul. 80- 62, 1980-1 C.B. at 64, also requires that “the employer reasonably limits payment of such travel expenses to those that are ordinary and necessary in the conduct of the trade or business”. Assuming the revenue rulings are consistent in terms of the amount applicable to meals under each ruling, it seems logical that $14 of the allowance petitioner paid would constitute the amount that the rulings accept as reasonable for meal expenses. This being so, petitioner would bear the burden of proving that the additional amount of the allowance for 14(...continued) 84-164, 1984-2 C.B. 63, to cover meals and incidental expenses).Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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