274(e) 4 & 5 vs. 132 (e)(1)
Posted: 15-Aug-2019 2:53pm
Good evening All,
I hope you are having a good day.
If you have a fishing trip in which all the employees are eligible to attend, and say 10 employees go and it costs $2,000. Under 274(e) 4 this is a tax deductible, and I believe 100%.
Is this deduction subject to the further test of 132(e)(1) De Minimis Fringe of
a. infrequent
b. so small as to make accounting unreasonable
For this example assume the $200 per person is accountable.
My thinking is the the deduction under 274(e) 4 is not subject to 132(e)(1).
Looking for a court case.
Thanks,
Art
I hope you are having a good day.
If you have a fishing trip in which all the employees are eligible to attend, and say 10 employees go and it costs $2,000. Under 274(e) 4 this is a tax deductible, and I believe 100%.
Is this deduction subject to the further test of 132(e)(1) De Minimis Fringe of
a. infrequent
b. so small as to make accounting unreasonable
For this example assume the $200 per person is accountable.
My thinking is the the deduction under 274(e) 4 is not subject to 132(e)(1).
Looking for a court case.
Thanks,
Art