UAL Corporation and Subsidiaries - Page 30

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               CHIECHI, J., concurring in part and dissenting in part:  I             
          concur in the majority’s holding that the per diem allowances for           
          day trips that United paid to its employees are deductible under            
          section 162(a)(1).  I dissent from the majority’s holding that              
          the per diem allowances for overnight trips that United paid to             
          its employees are deductible under section 162(a)(1).  I believe            
          that the amounts of such per diem allowances for overnight trips            
          claimed as deductions under section 162(a)(2) are deductible                
          under that section.                                                         

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