Because he would eat breakfast and lunch on the road, he deducted the cost of those meals from his 1960 and 1961 income tax return pursuant to § 162(a)(2) of the Internal Revenue Code.

Second, the requirement that the taxpayer must sleep away from home in order to qualify for a § 162(a)(2) deduction is a bright-line, easy to administer rule that avoids unnecessary litigation.

[7] “In this area of limitless factual variations, ‘it is the province of Congress and the Commissioner, not the courts, to make the appropriate adjustments.’”[2] Justices Douglas, Black and Fortas dissented on the ground that the phrase “while away from home” goes to geography and not time.

[2] The dissent argued that the majority’s approach of interpreting the phrase as “overnight” incorrectly switches the focus to a time element.

Furthermore, the decision puts all one-day travelers forced to pay for their meals on an equal footing when it comes to allowing a § 162(a)(2) business expense deduction.