TAX RESEARCH MEMORANDUM ASSIGNMENT 1

Devry ACCT 429 FEDERAL INCOME TAXATION COURSE PROJECT WEEK 7

TAX RESEARCH MEMORANDUM ASSIGNMENT 1

As we learned in Week 4, the Code allows taxpayers to take a deduction for the cost of meals when taxpayers have been deemed to be "away from home" for tax purposes. This determination can be difficult. Two separate clients came to you with questions as to whether they are entitled to take a deduction for the cost of meals incurred during a particular trip. The facts pertaining to each are:

1. Tracey is a sales representative for a national pharmaceutical company. She has a rather large sales territory, and she makes her rounds to her customers using a company-owned car over a 16- to 19-hour period of time. During these one-day business trips, Tracey will pull over in a suitable location (such as a park or a rest stop) and take a short nap in the backseat of her automobile.

2. Mark captains a ferryboat. This ferryboat carries tourists on roundtrips from Seattle to Victoria and back, each trip of which lasts from 15 to 17 hours and provides for a 6- to 7-hour layover in Victoria. During the layover, Mark typically takes a four-hour nap on a cot that he has stored in the pilothouse of the ferryboat.

Under each of these circumstances, if the taxpayer entitled to deduct the cost of meals purchased during the trip at issue?