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What is prorating with regard to the per diem deduction for pilots and flight attendants?

Prorate is a term used in IRS Publication 463 under the topic of the standard meal allowance.  The first day of a trip and the last day of a trip are subject to the prorating rules described in IRS Publication 463. The reason prorating is important to the standard meal allowance is because the first day and last day of a trip are considered partial days.  Because the first and last day are shortened, a taxpayer may be subject to a reduced (or prorated) standard meal allowance on those days. 

How is a partial day prorated in an M&IE calculation?

The following is an example:

Assume Amy, a flight attendant, is on a 4-day trip.  Amy is based in EWR so EWR is Amy's tax home.  On this particular 4-day trip, Amy has overnights (layovers) in LAX, TPA, and DFW respectively.

Notice that the last day of the trip where Amy returned to EWR uses the previous day for the layover city.  That is normal and can be found within IRS Publication 463.

How much gets prorated is subject for debate.  As of this writing, IRS Publication 463 says the following:

It is up to the tax preparer or taxpayer to interpret whether an airline pilot or flight attendant should use 75% or 100% on the first and last day of a trip.

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