- 24 - 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:Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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