117 T.C. No. 2
UNITED STATES TAX COURT
UAL CORPORATION AND SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18573-98. Filed July 13, 2001.
U, an international airline, paid its pilots and
flight attendants (collectively, employees) per diem
allowances. U paid the allowances to all employees;
i.e., those who departed from and returned to their
home bases on the same day and those who departed from
and returned to their home bases on different days. U
neither required nor received substantiation from the
employees as to their uses of the allowances.
Held: U may deduct the per diem allowances as
personal service compensation under sec. 162(a)(1),
I.R.C.
George B. Javaras, Todd F. Maynes, and Natalie Hoyer Keller,
for petitioner.
James C. Lanning, for respondent.
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