- 44 -
expenses was not at issue. Further, neither party herein relied
on nor even cited Kowalski.
Lastly, by recharacterizing the travel expenses as
deductible compensation for 1987 and later years, the portion of
the previously treated travel expenses that represented meal and
entertainment expenses become freed from the various percentage
limitations applicable thereto and become fully deductible. See
sec. 274(n). This is exactly what United is seeking to
accomplish in this case for 1987.
For the reasons stated, I dissent.
COHEN and COLVIN, JJ., agree with this dissenting opinion.
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