Tax Legal Services · Primary-source case analysis

Correll: Away-From-Home Meal Deductions Required Sleep or Rest

By Aneeta Mishra and Timothy Chan

Published August 20, 2026

United States v. Correll concerned a traveling food salesman who routinely left home early, ate breakfast and lunch on the road, and returned each evening without lodging or a sleep stop.

The Code’s away-from-home language needed an administrable boundary

The Treasury and IRS used a sleep-or-rest test to distinguish deductible travel from ordinary daily meal costs.

The rule reasonably implemented the statute

The Court deferred to the longstanding interpretation because it treated similarly situated taxpayers consistently and avoided fine distinctions based on hours or distance.

Long workdays alone were insufficient

A route could be lengthy and demanding without placing the taxpayer away from home in the tax sense required for meal deductions.

Current limitations and substantiation still apply

Even qualifying overnight travel must satisfy present section 162 and 274 rules, business purpose, tax-home doctrine, substantiation, percentage limits, and any applicable employee-expense restrictions.

Key takeaways

• Identify the tax home and each trip’s business purpose.
• Record departure, return, lodging, and required rest periods.
• Keep receipts or compliant per-diem records.
• Apply current meal-percentage and employee-deduction limitations.