I would love it if that were right. However, can you show me anything that supports your thoughts?
To me, Revenue Rule 99-7 says it is not deductible (start on the VERY bottom of page 5 for the "holding"):
<a href="
http://www.irs.gov/pub/irs-drop/rr-99-7.pdf#page=5" rel="nofollow" target="_blank">
http://www.irs.gov/pub/irs-drop/rr-99-7.pdf#page=5</a>
The 1993 "Walker" Tax Court case had supported your thoughts, but the IRS immediately came out with Revenue Rule 94-47 (and several follow-up Rules, including 99-7) to redefine the rules and say they will NOT be following the Walker decision.
