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eBook details

• Title: Eaton v. Evans
• Author : Federal Circuit U.S. Court of Appeals
• Release Date : January 02, 2000
• Genre: Law,Books,Professional & Technical,
• Pages : * pages
• Size : 52 KB

Description

In this federal employment taxes refund case, American Airlines, Inc. ("American") appeals from the final decision of the United States Court of Federal Claims granting the United States motion for summary judgment. See American Airlines, Inc. v. United States, 40 Fed. Cl. 712 (1998). We find that there remains no genuine issue of material fact and affirm the judgment of the Court of Federal Claims with regard to its grant of summary judgment on the issue of the American Express vouchers. We also affirm the judgment of the Court of Federal Claims on the issue whether Americans per diem allowances qualify as a working condition fringe benefit because the court correctly held that they are not excludable under Internal Revenue Code ("I.R.C.") § 132(a)(3). However, with regard to the Travel Expense Regulations, we find that a factual dispute exists as to whether American reasonably believed its per diem rates were at or below the actual expenses incurred by its employees during travel. Accordingly, we reverse the judgment of the Court of Federal Claims with regard to its grant of summary judgment that Americans refund claim was not supported by the Travel Expense Regulations, and remand the case to that court.

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