Quimbee logo
DMCA.com Protection Status
From our private database of 16,300+ case briefs...

Charley v. Commissioner

United States Court of Appeals for the Ninth Circuit
91 F.3d 72 (1996)


Philip Charley (defendant) served as President of Truesdail Laboratories (Truesdail). Charley frequently traveled for business and accrued many frequent flyer miles. At the time, Truesdail had an unwritten policy that any frequent flyer miles accrued during business travel were the personal property of the employees who accrued them. Throughout 1998, Charley took four business trips. Each time, Truesdail paid its travel agent funds to obtain first class airfare for Charley. But rather than purchasing a first class ticket, Charley instructed the agent to purchase a coach ticket with the funds. Charley would then upgrade the ticket to first class using his frequent flyer miles. The remainder of the original funds from Truesdail (the difference between a first class ticket and a coach ticket) was deposited into Charley’s personal travel account. In this manner, Charley “sold” his frequent flyer miles to Truesdail and received cash in exchange. By the end of the year, Charley had $3,149.93 deposited into his personal travel account. He did not report the amount on his tax return. The Tax Court ruled that the frequent flyer miles were taxable income.

Rule of Law


Holding and Reasoning (Farris, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 372,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 16,300 briefs, keyed to 223 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial