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expenses the costs he incurred in making trips from Jackson to
Mobile and his expenditures for meals and hotel rooms while in
Mobile. See id. at 468-469. With respect to the pursuit-of-
business condition, in the context of the facts before it in
Flowers, the Supreme Court said:
This means that there must be a direct connection
between the expenditure and the carrying on of the
trade or business of the taxpayer or his employer.
Moreover, such an expenditure must be necessary or
appropriate to the development and pursuit of the
business or trade.
Id. at 470. The Supreme Court dismissed almost summarily any
claim that the expenses in question had been incurred in pursuit
of the business of the corporation. See id. at 473. The Court
found that the expenses were no different in kind than the
commuting expenses incurred by employees residing in proximity to
their post of duty. See id. Such local commuting expenses the
Court characterized as “living and personal expenses lacking the
necessary direct relation to the prosecution of the [employer’s]
business.” Id. The Court found that the taxpayer’s added costs
of a long-distance commute "were as unnecessary and inappropriate
to the development of the railroad’s business”. Id. The
railroad, the Court stated, did not require the taxpayer to
travel on business from Jackson to Mobile or to maintain living
quarters in both cities: “It simply asked him to be at his
principal post in Mobile as business demanded and as his personal
convenience was served”. Id. The Court concluded:
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