05 Jun Question Haig Simmons was just hired by B&B
Question
Haig Simmons was just hired by B&B Restaurants, Inc., a Delaware Corporation domiciled in Colorado. Ms. Simmons maintains a residence in Orange County, California, so her children may attend the schools of her choice and so that her husband may be employed there as a leading plastic surgeon. B&B has just opened three (3) restaurants in Utah, Nevada, and Idaho. B&B requires Ms. Simmons set up the general ledger accounting system at each restaurant. B&B estimates it will take Ms. Simmons 14 months of continuous, full time work (40 hours per week, 4 weeks per month) to set up the systems. B&B requires Ms. Simmons to rotate her time. That is, to spend time at each restaurant at least once a calendar quarter. Each restaurant has an office for the accounting function, although the offices are so small that Ms. Simmons does a majority of her work from hotel rooms near the restaurants. Ms. Simmons reports back electronically to B&B. Ms. Simmons is never required to go to Colorado. B&B does not reimburse Ms. Simmons for her lodging, travel, or meal expenses. May Ms. Simmons deduct lodging, travel, and meal expenses? Note 1: Ignore limitations and phase-outs and cut backs and whether the putative deductions might be above the line or below the line. Ignore AMT. Note 2: This is your chance to
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