Charles A. Boyd and Darby A. Harvey - Page 14

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          rendered”, sec. 162(a)(1), and “traveling expenses (including               
          amounts expended for meals and lodging * * *) while away from               
          home in the pursuit of a trade or business”, sec. 162(a)(2).                
               Section 274(d) generally disallows any deduction under                 
          section 162 for, among other things, “any traveling expense                 
          (including meals and lodging while away from home)”, unless the             
          taxpayer complies with stringent substantiation requirements as             
          to the amount, time and place, and business purpose of the                  
          expense.  Sec. 274(d)(1).  Section 274(d) authorizes the                    
          Secretary to provide by regulations that some or all of these               
          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            








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