Facts: The Lucky Dogs (Dogs) are a team in the NHA, a professional hurling league consisting of 32 teams. The NHA requires teams to play both home and away games and requires teams to arrive in the away city at least twelve hours before the start of an away game. Player schedules in the away cities are very regimented and free time is limited. NHA teams travel with 15 to 18 players, a head coach, assistant coaches, medical personnel, athletic trainers, equipment managers, communications personnel, travel logistics managers and public relations/media personnel. As soon as the NHA releases game schedules, teams contact away city hotels to provide sleeping accommodations, space for athletic trainers to provide medical treatment and meal rooms where pregame meals and snacks are served. These pregame meals and snacks must meet specific nutritional guidelines and be of a specific type and quantity. The food is made available to all traveling employees in a private room with buffet stations. It is provided at no extra cost to the travelling employees. Meals are made available to all traveling employees, and attendance at breakfast and lunch is mandatory for all players. Players may be fined or scratched from participating in games if they are late to or absent from these meals. Mealtime also provides the Dogs with a chance to conduct team business e.g. meet with coaches, discuss strategy, adjust rosters and prepare for media inquiries. In addition to meals, players are provided with a pregame snack. This snack is provided in the designated private meal room. However, unlike breakfast and lunch, it is not mandatory for players to attend or eat these pregame snacks. After the pregame snack, and approximately two hours before game time, the Dogs’ board a charter bus and depart for the opponent’s arena. Upon arrival, the players stretch, put on their uniforms and play the game. After the conclusion of the game, players shower, change clothes, and meet with the media. They then board a charter bus and travel to the airport to fly home or on to the next away city. Answer the following question: Are the Lucky Dogs entitled to deduct, as a de minimis fringe benefit, the full cost of the pregame meals they provide to employees while at away city hotels, or, alternatively, is the deduction limited to 50% of the expenses for such meals?
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