Commissioner v. Flowers
Unites States Supreme Court
326 U.S. 465 (1946)
Flowers (plaintiff), an attorney, chose to keep living in Jackson, Mississippi, after accepting a general-counsel position headquartered in Mobile, Alabama, and deducted his regular travel, meals, and lodging costs between the two cities as business expenses. The Commissioner (defendant) disallowed the deductions, the Tax Court agreed with the Commissioner (finding Flowers's situation no different from an ordinary commuter choosing to live in one city and work in another), and the court of appeals reversed by construing "home" to mean Flowers's actual residence rather than his principal place of business.
Whether, to be deductible for federal tax purposes, travel expenses must be: (1) reasonable and necessary, (2) incurred while away from home, and (3) incurred by business necessity.