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United States v. Correll | 389 U.S. 299 (1967)
Section 162(a)(2) of the tax code provides a deduction for meal and lodging expenses incurred while away from home in the pursuit of a trade or business. The United States Supreme Court considered this section’s away from home requirement in the case of United States versus Correll.
Homer Correll was a grocery salesman who traveled to various restaurants making sales. He usually ate breakfast and lunch on his work route but returned home in time for dinner. On his federal income tax returns, Correll deducted these meal expenses as business-travel expenses under Section 162(a)(2) of the tax code.
The commissioner of internal revenue disallowed Correll’s deductions. The commissioner asserted that business-travel expenses were only deductible if the travel required overnight sleep or rest, which Correll’s job didn’t. Correll paid the deficiency and sued for a refund.
The district court found in favor of Correll, and the Sixth Circuit affirmed. The United States Supreme Court granted cert to resolve a circuit split over the proper interpretation of Section 162’s away from home requirement.
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