Nature of the Case
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Facts
P was a traveling salesman for a wholesale grocery company. He left home early in the morning, ate breakfast and lunch on the road, and returned home in time for dinner. P deducted the cost of his morning and noon meals as 'traveling expenses' incurred in the pursuit of his business 'while away from home' under § 162 (a)(2) D denied the deductions because the daily trips required neither sleep nor rest and that the cost of the meals was a 'personal, living' expense under §262 rather than a travel expense under §162 (a)(2). P sued for a refund in the District Court and got a favorable jury verdict. The Court of Appeals for the Sixth Circuit affirmed, holding that the Commissioner's sleep or rest rule is not 'a valid regulation under the present statute.' The Supreme Court granted certiorari.
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