Beech Trucking Company, Inc., Arthur Beech, Tax Matters Person - Page 9




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          substantiation requirements “shall not apply in the case of an              
          expense which does not exceed an amount prescribed pursuant to              
          such regulations.”                                                          
               Under section 274(n), the amount allowable as a deduction              
          for “any expense for food or beverages” is generally limited to             
          50 percent of the amount of the expense that would otherwise be             
          allowable.  Sec. 274(n)(1)(A).                                              
          B.   The Revenue Procedures                                                 
               Under the applicable section 274(d) regulations, the                   
          Commissioner is authorized to prescribe rules in pronouncements             
          of general applicability under which certain types of expense               
          allowances, including per diem allowances for ordinary and                  
          necessary expenses of traveling away from home, will be regarded            
          as satisfying the substantiation requirements of section 274(d).            
          Sec. 1.274(d)-1, Income Tax Regs.; see also sec. 1.274-5T(j),               
          Temporary Income Tax Regs., 50 Fed. Reg. 46032 (Nov. 6, 1985).              
          For purposes of these regulations, Rev. Proc. 94-77, 1994-2 C.B.            
          825, and Rev. Proc. 96-28, 1996-1 C.B. 686 (hereinafter referred            
          to collectively as the Revenue Procedures), authorize various               
          nonmandatory methods that taxpayers may elect to use, in lieu of            
          substantiating actual expenses, for deemed substantiation of                
          employee lodging, meal, and incidental expenses incurred while              










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