## Facts

- Homer O. Correll was a traveling salesman who routinely left home early, ate breakfast and lunch on the road, and returned home for dinner.
- On his 1960 and 1961 federal income tax returns, Correll deducted the cost of his morning and noon meals as “traveling expenses” incurred “while away from home” under I.R.C. § 162(a)(2).
- The Commissioner of Internal Revenue disallowed the meal deductions on the ground that Correll’s daily trips required neither sleep nor rest, making the expenses nondeductible personal living expenses under I.R.C. § 262.
- Correll paid the additional tax and sued for a refund; a jury returned a verdict for Correll in federal district court.
- The Sixth Circuit affirmed, holding the Commissioner’s “sleep or rest” rule invalid under the statute.
- The Supreme Court granted certiorari to resolve a circuit conflict concerning recurring administration of § 162(a)(2).

## Issues

1. Whether the Commissioner’s “sleep or rest” rule—allowing meal deductions under I.R.C. § 162(a)(2) only when business travel requires sleep or rest (typically overnight)—is a valid interpretation of “traveling expenses … while away from home.”

## Decision

- The Supreme Court reversed the Sixth Circuit and upheld the Commissioner’s disallowance of Correll’s meal deductions.
- The Court held that the Commissioner’s longstanding “sleep or rest” rule is a reasonable, authorized implementation of the statutory limitation “while away from home.”
- The Court concluded that same-day business travel not requiring sleep or rest does not qualify the taxpayer’s meals as deductible “traveling expenses” under § 162(a)(2).

## Legal Principles

- I.R.C. § 162(a)(2) provides a limited exception to the general rule that personal living expenses are not deductible; its scope is constrained by the statutory phrase “while away from home.”
- When a tax statute uses broad, administratively difficult language, the Commissioner may adopt a reasonable, uniform rule to implement it, and courts should sustain such a rule if it is not arbitrary.
- A bright-line rule that conditions meal deductibility on travel requiring sleep or rest may be sustained because it increases administrability and reduces litigation over fact-specific claims.
- The Commissioner may treat meal costs incurred on trips that do not require sleep or rest as nondeductible personal expenses rather than deductible travel expenses.

## Conclusion

The Court upheld the IRS “sleep or rest” test as a permissible construction of § 162(a)(2), making meal expenses on same-day business trips generally nondeductible because the travel does not place the taxpayer “away from home” in the sense required by the statute.


United States v. Correll, 389 U.S. 299 (1967)