Walter and Nancy Jacob v. United States

*1299I respectfully dissent as to all items which the majority deem deductible as “meals.”

Section 61(a) of the Internal Revenue Code of 1954 provides that “[ejxcept as otherwise provided in this subtitle, gross income means all income from whatever source derived. . . . ” 1

It is an established rule that exemptions from the broad definition of income in § 61 must be construed narrowly. Commissioner of Internal Revenue v. Jacobson, 336 U.S. 28, 49, 69 S.Ct. 358, 93 L.Ed. 477 (1949); United States v. Stewart, 311 U.S. 60, 71, 61 S.Ct. 102, 85 L.Ed. 40 (1940); Wilson v. United States, 412. F.2d 694,…