- 24 - section 4.03 of the revenue procedures. Therefore, his M&IE incurred during the years at issue are subject to the section 274(n)(1) 50-percent limitation. In the alternative, petitioner argues that if the 50-percent limitation under section 274(n)(1) applies, he is eligible for an exception. Section 274(n)(2) provides that paragraph (1) shall not apply to any expense if: (E) such expense is for food or beverages-- (i) required by any Federal law to be provided to crew members of a commercial vessel, (ii) provided to crew members of a commercial vessel-- (I) which is operating on the Great Lakes, the Saint Lawrence Seaway, or any inland waterway of the United States, and (II) which is of a kind which would be required by Federal law to provide food and beverages to crew members if it were operated at sea, * * * * * * * Clauses (i) and (ii) of subparagraph (E) shall not apply to vessels primarily engaged in providing luxury water transportation (determined under the principles of subsection (m)). * * * The evidence failed to show he qualified for an exception to the section 274(n)(1) 50-percent limitation. He did not demonstrate the company was required by any law to provide food or beverages to him or that the Clipper, the Clipper III, or thePage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011