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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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