Legal Opinion

Boyd Gaming Corp. v. Commissioner

United States Tax Court

Decided September 30, 1997No. Tax Ct. Dkt. No. 3433-95UnpublishedCited by 2 opinions

CALIFORNIA HOTEL & CASINO AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3434-95 Ps provide free meals to their employees in private cafeterias located on Ps' business premises. R determined that sec. 274(n)(1), I.R.C., limits Ps' deduction for the cost of these meals.

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CALIFORNIA HOTEL & CASINO AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3434-95 Ps provide free meals to their employees in private cafeterias located on Ps' business premises. R determined that sec. 274(n)(1), I.R.C., limits Ps' deduction for the cost of these meals. Ps argue that they may deduct 100 percent of their costs under the de minimis fringe benefit exception of sec. 274(n)(2)(B), I.R.C., which requires in this case that Ps provide the meals to each of substantially all of their employees for a substantial noncompensatory business reason.…

1Opinion of the Court

BOYD GAMING CORPORATION, F.K.A. THE BOYD GROUP AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Boyd Gaming Corp. v. Commissioner

Tax Ct. Dkt. No. 3433-95

United States Tax Court

T.C. Memo 1997-445; 1997 Tax Ct. Memo LEXIS 528; 74 T.C.M. (CCH) 759; T.C.M. (RIA) 97445;

September 30, 1997, Filed

CALIFORNIA HOTEL & CASINO AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 3434-95

Ps provide free meals to their employees in private cafeterias located on Ps' business premises. R determined that sec. 274(n)(1), I.R.C., limits Ps' deduction…

2Cases cited27 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Helvering v. CliffordSupreme Court of the United States · 1940
  3. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  4. United States v. BurkeSupreme Court of the United States · 1992
  5. Tokarski v. CommissionerUnited States Tax Court · 1986

22 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Boyd Gaming Corp. v. CommissionerCourt of Appeals for the Ninth Circuit · 1999
  2. Boyd Gaming Corporation, F.K.A. The Boyd Group and Subsidiaries v. Commissioner of Internal Revenue, California Hotel & Casino and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999

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