UAL Corporation and Subsidiaries v. Commissioner

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…