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On October 27, 2000, respondent sent a notice of deficiency
(notice) to petitioner. In that notice, respondent determined,
inter alia, that the limitation imposed by section 274(n)(1)
applied to the per diem amounts that TLC paid to its driver-
employees.
Respondent sent a notice to each of the following trucking
company clients of TLC in which respondent determined that each
such trucking company client had a deficiency in tax for one or
more taxable years31 arising out of such trucking company cli-
ent’s failure to take into account the limitation imposed by
section 274(n)(1)32 and with respect to which each such trucking
company client commenced proceedings in the Court, as follows:
31The record does not disclose the taxable year(s) to which
each of the notices issued to certain of TLC’s trucking company
clients pertained.
32See supra note 3.
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