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M&IE rate for the locality of travel for each calendar day (or
part thereof) that she is away from home for the 1997 tax year,
under Rev. Proc. 96-64 sec. 5.03, 1996-2 C.B. at 429, or a
prorated amount for the 1998 and 1999 tax years, under Rev. Proc.
97-59 secs. 5.03, 6.04, 1997-2 C.B. at 597, 600, and Rev. Proc.
98-64 secs. 5.03, 6.04, 1998-2 C.B. at 828, 831, respectively.
Petitioners deducted 50 percent of the actual expenses that
Mrs. Whitehurst incurred for meals consumed while she traveled to
and from and competed in bowling tournaments. Respondent allowed
petitioners deductions for the M&IE rate only for days that Mrs.
Whitehurst actually competed in a bowling tournament, but not for
days when she traveled to and from each tournament.
Mrs. Whitehurst produced a small number of receipts from
grocery stores and restaurants. Because respondent has already
conceded that petitioners are entitled to use the M&IE rate in
lieu of actual expenses, we allow petitioners deductions for the
M&IE rate in lieu of actual meal expenses during days Mrs.
Whitehurst traveled to and from and competed in bowling
tournaments. Mrs. Whitehurst is entitled to use the M&IE rate
for 44 days in 1997, 33 days in 1998, and 27 days in 1999, and
the M&IE rate for travel to a high-cost locality for 4 days of
travel in 1998 and 9 days in 1999.
e. Other (Entry Fees)
Petitioners produced fliers from bowling tournaments and
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