United States v. Correll

Holding

Travel meal expenses are deductible only when the travel involves an overnight stay or other rest period requiring the taxpayer to be away from home.

Facts

Correll was a traveling salesman who deducted meals consumed during one-day trips that did not include an overnight stay.

Reasoning

Justice Stewart held that the IRS's overnight-stay test was a reasonable interpretation of Section 162(a)(2)'s 'while away from home' language. This is the origin of the modern overnight rule for business-travel meal deductions.