Transport Labor Contract/Leasing, Inc. & Subsidiaries - Page 39

                                       - 39 -39                                           
          able as a deduction for food or beverage expenses:                          
               SEC. 274.  DISALLOWANCE OF CERTAIN ENTERTAINMENT, ETC.,                
                    EXPENSES.                                                         
                  *       *       *       *       *       *       *                   
                    (n) Only 50 Percent of Meal * * * Expenses Allowed                
               as Deduction.--                                                        
                         (1) In general.--The amount allowable as a                   
                    deduction under this chapter for--                                
                              (A) any expense for food or bever-                      
                         ages, * * *                                                  
                  *       *       *       *       *       *       *                   
               shall not exceed 50[33] percent of the amount of such                  
               expense or item which would (but for this paragraph) be                
               allowable as a deduction under this chapter.                           
               Section 274(n)(2) provides certain exceptions to the section           
          274(n)(1) limitation, including the following:                              
                    (2) Exceptions.--Paragraph (1) [of section 274(n)]                
               shall not apply to any expense if--                                    
                         (A) such expense is described in paragraph                   
                    (2), (3), (4), (7), (8), or (9) of subsection (e).                
               The exceptions to the section 274(n)(1) limitation provided            
          by section 274(e)(3) (section 274(e)(3) exceptions) are for:                
                    (3) Reimbursed expenses.--Expenses paid or in-                    
               curred by the taxpayer, in connection with the perfor-                 
               mance by him of services for another person (whether or                
               not such other person is his employer), under a reim-                  
               bursement or other expense allowance arrangement with                  
               such other person, but this paragraph shall apply--                    
                         (A) where the services are performed for                     
                    an employer, only if the employer has not                         

               33See supra note 3.                                                    





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