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NOTES 323 Tax Lawyer, Vol. 56, No. 1 NOTE THE FRIENDLY SKIES: PER DIEM ALLOWANCES TO AIRLINE EMPLOYEES DEEMED COMPENSATION IN UAL CORPORATION V. COMMISSIONER In UAL Corporation and Subsidiaries v. Commissioner,1 the United States Tax Court held that per diem allowances paid to traveling employees were deductible as personal service compensation under section 162(a)(1) of the Code. Part I of this Note presents the factual and regulatory framework of UAL. Part II provides the parties’ arguments...

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