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United States v. Correll

United States Supreme Court
389 U.S. 299 (1967)


Facts

Homer Correll (plaintiff), a traveling grocery salesman, usually ate breakfast and lunch on his work route and returned home in time for dinner. Correll deducted the cost of these meals from his gross income as business-travel expenses under § 162(a)(2) of the Internal Revenue Code of 1954 (tax code). However, the commissioner of internal revenue (commissioner) (defendant) did not treat business-travel expenses as tax deductible unless the taxpayer’s travel required overnight sleep or rest, which Correll’s job did not require. The commissioner disallowed Correll’s deduction. Correll paid the tax and sued for a refund, challenging the disallowance. The district court found for Correll, and the United States Court of Appeals for the Sixth Circuit affirmed. The United States Supreme Court granted certiorari to resolve a circuit split over the proper interpretation of § 162(a)(2).

Rule of Law

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Issue

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Holding and Reasoning (Stewart, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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