FACTS: Plaintiff salesman regularly traveled an extensive sales territory. Five or six times a year, plaintiff returned to New York and spent several days at his employers' offices performing services essential to his work. Plaintiff previously maintained a family home then used his brother's home as his personal residential address and a cousin's address for automobile registration. Plaintiff had no permanent abode anywhere. The Internal Revenue commissioner disallowed plaintiff's deduction for meals and lodging, under I.R.C. § 162(a)(2), because he had no home to be away from while traveling.
CONCLUSION: The court affirmed the district court judgment dismissing appellant's complaint; court could not read statutory language allowing deductions away from home to apply to those without a home.
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