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UAL CORP. & SUBS. v. COMMISSIONER

Docket No. 18573-98.

117 T.C. 7 (2001)

117 T.C. No. 2

UAL CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 13, 2001.

Attorney(s) appearing for the Case

George B. Javaras and Todd F. Maynes, for petitioner.

James C. Lanning, for respondent.

LARO, Judge:

Respondent determined deficiencies of $1,478,718, $61,867,523, $1,751,161, and $45,981,293 in petitioner's 1983, 1984, 1986, and 1987 Federal income taxes, respectively.1 Following concessions, we must decide whether petitioner may deduct the per diem allowances paid to its flight attendants and pilots (collectively, employees) for day trips and overnight trips (as defined below). We hold it may deduct the per diem...

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