Boyd Gaming Corp. v. Commissioner

177 F.3d 1096 (1999)

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Boyd Gaming Corp. v. Commissioner

United States Court of Appeals for the Ninth Circuit
177 F.3d 1096 (1999)

Facts

California Hotel and Casino, Boyd Gaming Corporation, and their subsidiaries (Boyd) (plaintiffs) operated hotel and casino properties in Las Vegas. Boyd employees were required to remain on site for meals and, as a result, received free meals at company cafeterias. Boyd cited several justifications for the rule requiring employees to remain on site, including security and efficiency, work-force control, and lack of dining options nearby. For tax years 1987 and 1988, Boyd deducted 100 percent of the expenses related to the cafeteria meals. The commissioner of internal revenue (defendant) issued deficiency notices based on the deductions, and Boyd petitioned for redetermination by the United States Tax Court. The tax court held that Boyd’s deductions for the cafeteria meals were limited to 80 percent of associated expenses pursuant to Internal Revenue Code § 274(n). Boyd appealed.

Rule of Law

Issue

Holding and Reasoning (McKeown, J.)

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Federal Income Tax

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