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We conclude that AIM’s reimbursements to petitioner for golf
expenses in 1995 and 1996 are constructive dividends to
petitioner.
F. Meal Expenses
Petitioner paid meal expenses for AIM employees of $288 in
1994, $390 in 1995, and $322 in 1996. AIM reimbursed those
amounts to petitioner and deducted one-half, or $144 in 1994,
$195 in 1995, and $161 in 1996. Respondent contends that AIM is
not entitled to the deductions and that those amounts are
constructive dividends to petitioner. We disagree.
A taxpayer may deduct meal expenses under section 162 if
they are ordinary and necessary business expenses and if he or
she meets the substantiation requirements of section 274(d).
Moss v. Commissioner, 758 F.2d 211, 212 (7th Cir. 1985), affg. 80
T.C. 1073 (1983). Petitioners have met these requirements.
Petitioner paid these expenses for meals eaten by AIM’s employees
working overtime at jobsites. Thus, AIM may deduct its
reimbursement to petitioner of $288 in 1994, $390 in 1995, and
$322 in 1996 for meal expenses. Those amounts are not
constructive dividends to petitioner.
G. Travel Expenses
AIM deducted $4,200 more than respondent allowed for 1994
for travel expenses by AIM employees. Petitioners contend that
AIM properly deducted the $4,200 because Mrs. Boler incurred
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