326 U.S. 465 (1946)
Commissioner v. Flowers is a foundational federal income tax case governing when a taxpayer may deduct travel, meals, and lodging as business expenses while "away from home." The decision addresses the recurring problem of taxpayers who maintain a personal residence in one city but whose principal place of employment is in another.
Are travel, meals, and lodging expenses incurred by a taxpayer who chooses to reside in a city different from his principal place of employment deductible as "traveling expenses ... while away from home in the pursuit of a trade or business," when the separation of residence and workplace is due to personal convenience rather than business necessity?
Under IRC § 23(a)(1)(A) (now § 162(a)(2)), a taxpayer may deduct traveling expenses, including meals and lodging, only if: (1) the expenses are reasonable and necessary traveling expenses; (2) they are incurred while the taxpayer is away from "home"; and (3) they are incurred in the pursuit of the taxpayer's trade or business—that is, they bear a direct connection to the business and are required by the business's exigencies, not by the taxpayer's personal conveniences. Expenses attributable to maintaining a personal residence at a distance from the principal place of employment are personal or commuting expenses and are not deductible.
No. The claimed travel, meals, and lodging expenses were not incurred in pursuit of the employer's business but arose from Flowers's personal decision to maintain his residence in a different city from his principal place of employment; therefore, they are not deductible.
Flowers established the enduring three-part test for deducting travel expenses under what is now § 162(a)(2) and underscored that business necessity—not personal convenience—controls deductibility. The case anchors the "tax home" framework used to differentiate between deductible travel away from a business base and nondeductible commuting or dual-residence costs. It informs subsequent cases on temporary assignments, multi-location work, and the line between living expenses and business outlays, making it a cornerstone for understanding the business-personal boundary in federal income tax law.