Commissioner v. Flowers, 326 U.S. 465 (1946), was a Federal income tax case before the Supreme Court of the United States.

Where attorney preferred for personal reasons to live in a different state from the location of his employer's principal office, and his duties required frequent trips to that office, the evidence sustained Tax Court's finding that the necessary relation between expenses of such trips and the railroad's business was lacking.

[2] The Court heard the issue of whether the taxpayer could deduct the costs incurred to travel between Jackson and Mobile from his taxes.

[4] The relevant test for deductibility was whether the travel had been motivated by “exigencies of business” or by considerations of personal preference.

[5] The court opined, “[t]he facts demonstrate clearly that the expenses were not incurred in the pursuit of the business of the taxpayer's employer, the railroad.”[4] The court further held that the expenses in question “…were incurred solely as the result of the taxpayer’s desire to maintain a home in Jackson while working in Mobile, a factor irrelevant to the maintenance and prosecution of the railroad’s legal business.”[4] The court determined that the relevant test for deductibility was whether the travel had been motivated by “exigencies of business” or by considerations of personal preference.