The TAM separately considers whether the value of snacks provided to employees is excludable from income under Section 119. Rather than revisit the business reasons previously analyzed, the TAM relies on Tougher v. Commissioner, 441 F.2d 1148 (9th Cir. 1971), to determine that the snacks are not meals. Accordingly, a snack cannot be a meal furnished for the convenience of the employer. Nevertheless, the TAM does conclude that the value of the snacks is excludable from employee income as de minimis fringe benefits under Section 132(e)(1)."
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