Henderson v. Commissioner

James Henderson (plaintiff) toured with a traveling ice show based in Virginia but contributed minimally to his parents' Idaho household, where he stored belongings and his dog, held an Idaho license, voted, banked, and paid taxes. Between tours he returned to Idaho, did minor jobs, and made little effort to find other work. He deducted his touring travel expenses under section 162(a)(2) as travel 'away from home'; the Commissioner (defendant) disallowed the deduction, and the tax court agreed.

Whether an itinerant taxpayer with no fixed tax home is eligible for a business-travel expense deduction under federal tax law.