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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).
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