LEVIN H. CAMPBELL, Circuit Judge.
The Commissioner of Internal Revenue (Commissioner) appeals a decision of the United States Tax Court that allowed a deduction under 26 U.S.C. § 162(a)(2) (1976) for expenses incurred by a law student in the course of her summer employment. The facts in the case are straightforward and undisputed.
[249]*249In the fall of 1973 Catharine Hantzis (taxpayer), formerly a candidate for an advanced degree in philosophy at the University of California at Berkeley, entered Harvard Law School in Cambridge, Massachusetts, as a full-time student. During her second year of law school she sought unsuccessfully to obtain employment for the summer of 1975 with a Boston law firm. She did, however, find a job as a legal assistant with a law firm in New York City, where she worked for ten weeks beginning in June 1975. Her husband, then a member of the faculty of Northeastern University with a teaching schedule for that summer, remained in Boston and lived at the couple’s home there. At the time of the Tax Court’s decision in this case, Mr. and Mrs. Hantzis still resided in Boston.
On their joint income tax return for 1975, Mr. and Mrs. Hantzis reported the earnings from taxpayer’s summer employment ($3,750) and deducted the cost of transportation between Boston and New York, the cost of a small apartment rented by Mrs. Hantzis in New York and the cost of her meals in New York ($3,204). The deductions were taken under 26 U.S.C. § 162(a)(2) (1976), which provides:
“§ 162. Trade or business expenses (a) In general. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including—
(2) traveling expenses (including amounts expended for meals and lodging other than amounts which are lavish or extravagant under the circumstances) while away from home in the pursuit of a trade or business .... ”
The Commissioner disallowed the deduction on the ground that taxpayer’s home for purposes of section 162(a)(2) was her place of employment and the cost of traveling to and living in New York was therefore not “incurred ... while away from home.” The Commissioner also argued that the expenses were not incurred “in the pursuit of a trade or business.” Both positions were rejected by the Tax Court, which found that Boston was Mrs. Hantzis’ home because her employment in New York was only temporary and that her expenses in New York were “necessitated” by her employment there. The court thus held the expenses to be deductible under section 162(a)(2).1
In asking this court to reverse the Tax Court’s allowance of the deduction, the Commissioner has contended that the expenses were not incurred “in the pursuit of a trade or business.” We do not accept this argument; nonetheless, we sustain the Commissioner and deny the deduction, on the basis that the expenses were not incurred “while away from home.”
I.
Section 262 of the Code, 26 U.S.C. § 262 (1976), declares that “except as otherwise provided in this chapter, no deductions shall be allowed for personal, living, or family expenses.” Section 162 provides less of an exception to this rule than it creates a separate category of deductible business expenses. This category manifests a fundamental principle of taxation: that a person’s taxable income should not include the cost of producing that income. See Note, The Additional Expense Test: A Proposal to Help Solve the Dilemma of Mixed Business and Personal Expenses, 1974 Duke L.J. 636, 636. “[Ojne of the specific examples given by Congress” of a deductible cost of producing income is travel expenses in section 162(a)(2). Commissioner v. Flowers, 326 U.S. 465, 469, 66 S.Ct. 250, 252, 90 L.Ed. 203 (1946). See Rev.Rul. 60-16,1960-1 C.B. 58, 60.
The test by which “personal” travel expenses subject to tax under section 262 are distinguished from those costs of travel necessarily incurred to generate income is em[250]*250bodied in the requirement that, to be deductible under section 162(a)(2), an expense must be “incurred ... in the pursuit of a trade or business.” In Flowers the Supreme Court read this phrase to mean that “[t]he exigencies of business rather than the personal conveniences and necessities of the traveler must be the motivating factors." 326 U.S. at 474, 66 S.Ct. at 254.2 Of course, not every travel expense resulting from business exigencies rather than personal choice is deductible; an expense must also be “ordinary and necessary” and incurred “while away from home.” 26 U.S.C. § 162(a)(2) (1976); Flowe rs, 326 U.S. at 470, 66 S.Ct. at 252. But the latter limitations draw also upon the basic concept that only expenses necessitated by business, as opposed to personal, demands may be excluded from the calculation of taxable income.
With these fundamentals in mind, we proceed to ask whether the cost of taxpayer’s transportation to and from New York, and of her meals and lodging while in New York, was incurred “while away from home in the pursuit of a trade or business.”
II.
The Commissioner has directed his argument at the meaning of “in pursuit of a trade or business.” He interprets this phrase as requiring that a deductible traveling expense be incurred under the demands of a trade or business which predates the expense, /. e., an “already existing” trade or business. Under this theory, section 162(a)(2) would invalidate the deduction taken by the taxpayer because she was a full-time student before commencing her summer work at a New York law firm in 1975 and so was not continuing in a trade or business when she incurred the expenses of traveling to New York and living there while her job lasted.3 The Commissioner’s proposed interpretation erects at the threshold of deductibility under section 162(a)(2) the requirement that a taxpayer be engaged in a trade or business before incurring a travel expense. Only if that requirement is satisfied would an inquiry into the deductibility of an expense proceed to ask whether the expense was a result of business exigencies, incurred while away from home, and reasonable and necessary.
Such a reading of the statute is semantically possible and would perhaps expedite the disposition of certain cases.4 Nevertheless, we reject it as unsupported by case law and inappropriate to the policies behind section 162(a)(2).
The two cases relied on by the Commissioner do not appear to us to establish that traveling expenses are deductible only if incurred in connection with a preexisting trade or business. The seminal interpretation of section 162(a)(2), Flowers v. Commissioner, supra, 326 U.S. 465, 66 S.Ct. 250, 90 L.Ed. 203, is as equivocal upon that point as the statutory language it construes. Commissioner v. Janss,
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LEVIN H. CAMPBELL, Circuit Judge.
The Commissioner of Internal Revenue (Commissioner) appeals a decision of the United States Tax Court that allowed a deduction under 26 U.S.C. § 162(a)(2) (1976) for expenses incurred by a law student in the course of her summer employment. The facts in the case are straightforward and undisputed.
[249]*249In the fall of 1973 Catharine Hantzis (taxpayer), formerly a candidate for an advanced degree in philosophy at the University of California at Berkeley, entered Harvard Law School in Cambridge, Massachusetts, as a full-time student. During her second year of law school she sought unsuccessfully to obtain employment for the summer of 1975 with a Boston law firm. She did, however, find a job as a legal assistant with a law firm in New York City, where she worked for ten weeks beginning in June 1975. Her husband, then a member of the faculty of Northeastern University with a teaching schedule for that summer, remained in Boston and lived at the couple’s home there. At the time of the Tax Court’s decision in this case, Mr. and Mrs. Hantzis still resided in Boston.
On their joint income tax return for 1975, Mr. and Mrs. Hantzis reported the earnings from taxpayer’s summer employment ($3,750) and deducted the cost of transportation between Boston and New York, the cost of a small apartment rented by Mrs. Hantzis in New York and the cost of her meals in New York ($3,204). The deductions were taken under 26 U.S.C. § 162(a)(2) (1976), which provides:
“§ 162. Trade or business expenses (a) In general. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including—
(2) traveling expenses (including amounts expended for meals and lodging other than amounts which are lavish or extravagant under the circumstances) while away from home in the pursuit of a trade or business .... ”
The Commissioner disallowed the deduction on the ground that taxpayer’s home for purposes of section 162(a)(2) was her place of employment and the cost of traveling to and living in New York was therefore not “incurred ... while away from home.” The Commissioner also argued that the expenses were not incurred “in the pursuit of a trade or business.” Both positions were rejected by the Tax Court, which found that Boston was Mrs. Hantzis’ home because her employment in New York was only temporary and that her expenses in New York were “necessitated” by her employment there. The court thus held the expenses to be deductible under section 162(a)(2).1
In asking this court to reverse the Tax Court’s allowance of the deduction, the Commissioner has contended that the expenses were not incurred “in the pursuit of a trade or business.” We do not accept this argument; nonetheless, we sustain the Commissioner and deny the deduction, on the basis that the expenses were not incurred “while away from home.”
I.
Section 262 of the Code, 26 U.S.C. § 262 (1976), declares that “except as otherwise provided in this chapter, no deductions shall be allowed for personal, living, or family expenses.” Section 162 provides less of an exception to this rule than it creates a separate category of deductible business expenses. This category manifests a fundamental principle of taxation: that a person’s taxable income should not include the cost of producing that income. See Note, The Additional Expense Test: A Proposal to Help Solve the Dilemma of Mixed Business and Personal Expenses, 1974 Duke L.J. 636, 636. “[Ojne of the specific examples given by Congress” of a deductible cost of producing income is travel expenses in section 162(a)(2). Commissioner v. Flowers, 326 U.S. 465, 469, 66 S.Ct. 250, 252, 90 L.Ed. 203 (1946). See Rev.Rul. 60-16,1960-1 C.B. 58, 60.
The test by which “personal” travel expenses subject to tax under section 262 are distinguished from those costs of travel necessarily incurred to generate income is em[250]*250bodied in the requirement that, to be deductible under section 162(a)(2), an expense must be “incurred ... in the pursuit of a trade or business.” In Flowers the Supreme Court read this phrase to mean that “[t]he exigencies of business rather than the personal conveniences and necessities of the traveler must be the motivating factors." 326 U.S. at 474, 66 S.Ct. at 254.2 Of course, not every travel expense resulting from business exigencies rather than personal choice is deductible; an expense must also be “ordinary and necessary” and incurred “while away from home.” 26 U.S.C. § 162(a)(2) (1976); Flowe rs, 326 U.S. at 470, 66 S.Ct. at 252. But the latter limitations draw also upon the basic concept that only expenses necessitated by business, as opposed to personal, demands may be excluded from the calculation of taxable income.
With these fundamentals in mind, we proceed to ask whether the cost of taxpayer’s transportation to and from New York, and of her meals and lodging while in New York, was incurred “while away from home in the pursuit of a trade or business.”
II.
The Commissioner has directed his argument at the meaning of “in pursuit of a trade or business.” He interprets this phrase as requiring that a deductible traveling expense be incurred under the demands of a trade or business which predates the expense, /. e., an “already existing” trade or business. Under this theory, section 162(a)(2) would invalidate the deduction taken by the taxpayer because she was a full-time student before commencing her summer work at a New York law firm in 1975 and so was not continuing in a trade or business when she incurred the expenses of traveling to New York and living there while her job lasted.3 The Commissioner’s proposed interpretation erects at the threshold of deductibility under section 162(a)(2) the requirement that a taxpayer be engaged in a trade or business before incurring a travel expense. Only if that requirement is satisfied would an inquiry into the deductibility of an expense proceed to ask whether the expense was a result of business exigencies, incurred while away from home, and reasonable and necessary.
Such a reading of the statute is semantically possible and would perhaps expedite the disposition of certain cases.4 Nevertheless, we reject it as unsupported by case law and inappropriate to the policies behind section 162(a)(2).
The two cases relied on by the Commissioner do not appear to us to establish that traveling expenses are deductible only if incurred in connection with a preexisting trade or business. The seminal interpretation of section 162(a)(2), Flowers v. Commissioner, supra, 326 U.S. 465, 66 S.Ct. 250, 90 L.Ed. 203, is as equivocal upon that point as the statutory language it construes. Commissioner v. Janss, 260 F.2d 99 (8th Cir. 1958), a case with facts somewhat akin to the present, did not articulate any such [251]*251theory. In Janss, a college student from Des Moines, Iowa, worked in Alaska during the summer between his freshman and sophomore years of school and sought to deduct from his taxable income the cost of transportation to and from Alaska as well as the cost of meals and lodging while there. Despite testimony from the personnel manager of the construction company for which Janss worked indicating that workers were available in Alaska and that Janss had been employed there largely as a personal favor, the Tax Court allowed the deduction. The Eighth Circuit reversed. It held, under Flowers, that Janss’ travel to Alaska was not motivated by the exigencies of the employer’s business. 260 F.2d at 104. The Eighth Circuit placed no emphasis on the fact that Janss had no previously existing trade or business.5
Nor would the Commissioner’s theory mesh with the policy behind section 162(a)(2). As discussed, the travel expense deduction is intended to exclude from taxable income a necessary cost of producing that income. Yet the recency of entry into a trade or business does not indicate that travel expenses are not a cost of producing income. To be sure, the costs incurred by a taxpayer who leaves his usual residence to begin a trade or business at another location may not be truly travel expenses, i. e., expenses incurred while “away from home,” see infra, but practically, they are as much incurred “in the pursuit of a trade or business” when the occupation is new as when it is old.
An example drawn from the Commissioner’s argument illustrates the point. The Commissioner notes that “if a construction worker, who normally works in Boston for Corp. A, travels to New York to work for Corp. B for six months, he is traveling .. . in the pursuit of his own trade as a construction worker.” Accordingly, the requirement that travel expenses be a result of business exigencies is satisfied. Had a construction worker just entering the labor market followed the same course his expenses under the Commissioner’s reasoning would not satisfy the business exigencies requirement.6 Yet in each case, the taxpayer’s travel expenses would be costs of earning an income and not merely incidents of personal lifestyle. Requiring that the finding of business exigency necessary to deductibility under section 162(a)(2) be predicated upon the prior existence of a trade or business would thus captiously restrict the meaning of “in pursuit of a trade or business.”
Insofar as any cases bear on the issue, they seem to support this conclusion. In United States v. LeBlanc, 278 F.2d 571 (5th Cir. 1960), a justice of the Louisiana supreme court who resided in Napoleanville sought to deduct as a travel expense the cost of an apartment in New Orleans, where the court sat. Because Louisiana law required justices both to maintain a residence in their home districts and be present at court functions, the cost of the apartment was found to have been necessitated by business exigencies.7 Such a result [252]*252is inconsistent with the rule proposed by the Commissioner. The taxpayer in LeBlanc was not previously engaged in the trade or business which he began upon arriving in New Orleans. At least for the period of his first term on the court, therefore, the taxpayer’s expenses in New Orleans were not incurred in connection with an already existing occupation and so, by the Commissioner’s reasoning, should have been disallowed.8 In another case, Kroll v. Commissioner, 49 T.C. 557 (1968), the court expressly found that the taxpayer, an eight-year-old actor, was not engaged in an already existing trade or business. Indeed, before coming to New York to begin acting, he “had never engaged in a trade or business.” 49 T.C. at 558. That this fact might have been dispositive was never mentioned by the court, which noted that the expenses in question were incurred in connection with an ongoing trade or business, id., at 561, and so went on to address the requirement that they have arisen while away from home.
In other contexts the phrase “in the pursuit of a trade or business” may permit the interpretation urged upon us by the Commissioner,9 but to require under section 162(a)(2) that a travel expense be incurred in connection with a preexisting trade or business is neither necessary nor appropriate to effectuating the purpose behind the use of that phrase in the provision. Accordingly, we turn to the question whether, in the absence of the Commissioner’s proposed threshold limit on deductibility, the expenses at issue here satisfy the requirements of section 162(a)(2) as interpreted in Flowers v. Commissioner.
III.
As already noted, Flowers construed section 162(a)(2) to mean that a traveling expense is deductible only if it is (1) reasonable and necessary, (2) incurred while away from home, and (3) necessitated by the exigencies of business. Because the Commissioner does not suggest that Mrs. Hantzis’ expenses were unreasonable or unnecessary, we may pass directly to the remaining requirements. Of these, we find dispositive the requirement that an expense be incurred while away from home. As we think Mrs. Hantzis’ expenses were not so incurred, we hold the deduction to be improper.
The meaning of the term “home” in the travel expense provision is far from clear. When Congress enacted the travel expense deduction now codified as section 162(a)(2), it apparently was unsure whether, to be deductible, an expense must be incurred away from a person’s residence or away from his principal place of business. See Note, A House is not a Tax Home, 49 Va.L.Rev. 125,127-28 (1963). This ambiguity persists and courts, sometimes within a single circuit, have divided over the issue. Compare Six v. United States, 450 F.2d 66 (2d Cir. 1971) (home held to be residence) and Rosenspan v. United States, 438 F.2d 905 (2d Cir.), cert. denied, 404 U.S. 864, 92 S.Ct. 54, 30 L.Ed.2d 281 (1971) and Burns v. Gray, 287 F.2d 698 (6th Cir. 1961) and Wallace v. Commissioner, 144 F.2d 407 (9th Cir. [253]*2531944) with Markey v. Commissioner, 490 F.2d 1249 (6th Cir. 1974) (home held to be principal place of business) and Curtis v. Commissioner, 449 F.2d 225 (5th Cir. 1971) and Wills v. Commissioner, 411 F.2d 537 (9th Cir. 1969).10 It has been suggested that these conflicting definitions are due to the enormous factual variety in the cases. See Bell v. United States, 591 F.2d 647, 649 (Ct.Cl.1979) (“We believe that much of the problem in differing definitions is the result of attempting to conceptualize the reasons for decisions which are based on widely varying factual situations.”); Brandi v. Commissioner, 513 F.2d 697, 699 (6th Cir. 1975) (“Because of the almost infinite variety of the factual situations involved, the courts have not formulated a concrete definition of the term ‘home’ capable of universal application.”) We find this observation instructive, for if the cases that discuss the meaning of the term “home” in section 162(a)(2) are interpreted on the basis of their unique facts as well as the fundamental purposes of the travel expense provision, and not simply pinioned to one of two competing definitions of home, much of the seeming confusion and contradiction on this issue disappears and a functional definition of the term emerges.
We begin by recognizing that the location of a person’s home for purposes of section 162(a)(2) becomes problematic only when the person lives one place and works another. Where a taxpayer resides and works at a single location, he is always home, however defined; and where a taxpayer is constantly on the move due to his work, he is never “away” from home. (In the latter situation, it may be said either that he has no residence to be away from, or else that his residence is always at his place of employment. See Rev.Rul. 60-16, 1960-1 C.B. 58, 62.) However, in the present case, the need to determine “home” is plainly before us, since the taxpayer resided in Boston and worked, albeit briefly, in New York.
We think the critical step in defining “home” in these situations is to recognize that the “while away from home” requirement has to be construed in light of the further requirement that the expense be the result of business exigencies. The traveling expense deduction obviously is not intended to exclude from taxation every expense incurred by a taxpayer who, in the course of business, maintains two homes. Section 162(a)(2) seeks rather “to mitigate the burden of the taxpayer who, because of the exigencies of his trade or business, must maintain two places of abode and thereby incur additional and duplicate living expenses.” Kroll, supra, 49 T.C. at 562 (emphasis added). See Brandl, supra, 513 F.2d at 699; Daly, supra, 72 T.C. at 195. Consciously or unconsciously, courts have effectuated this policy in part through their interpretation of the term “home” in section 162(a)(2). Whether it is held in a particular decision that a taxpayer’s home is his residence or his principal place of business, the ultimate allowance or disallowance of a deduction is a function of the court’s assessment of the reason for a taxpayer’s maintenance of two homes. If the reason is perceived to be personal, the taxpayer’s home will generally be held to be his place of employment rather than his residence and the deduction will be denied. See, e. g., Markey, supra, 490 F.2d at 1252-55; Wills, supra, 411 F.2d at 540-41; Daly, supra, 72 T.C. at 195-98; Lindsay v. Commissioner, supra, 34 B.T.A. at 843-44. If the reason is felt to be business exigencies, the person’s home will usually be held to be his residence and the deduction will be allowed. See, e. g., Frederick v. United States, 603 F.2d 1292 (8th Cir. 1979); Wright v. Hartsell, 305 F.2d 221 (9th Cir. 1962); Harvey v. Commissioner, 283 F.2d 491 (9th Cir. 1960); LeBlanc, supra, 278 F.2d 571. We understand the concern of the concurrence that such an operational interpretation of the term “home” is somewhat technical and perhaps [254]*254untidy, in that it will not always afford bright line answers, but we doubt the ability of either the Commissioner or the courts to invent an unyielding formula that will make sense in all cases. The line between personal and business expenses winds through infinite factual permutations; effectuation of the travel expense provision requires that any principle of decision be flexible and sensitive to statutory policy.
Construing in the manner just described the requirement that an expense be incurred “while away from home,” we do not believe this requirement was satisfied in this case. Mrs. Hantzis’ trade or business did not require that she maintain a home in Boston as well as one in New York. Though she returned to Boston at various times during the period of her employment in New York, her visits were all for personal reasons. It is not contended that she had a business connection in Boston that necessitated her keeping a home there; no professional interest was served by maintenance of the Boston home — as would have been the case, for example, if Mrs. Hantzis had been a lawyer based in Boston with a New York client whom she was temporarily serving. The home in Boston was kept up for reasons involving Mr. Hantzis, but those reasons cannot substitute for a showing by Mrs. Hantzis that the exigencies of her trade or business required her to maintain two homes.11 Mrs. Hantzis’ decision to keep two homes must be seen as a choice dictated by personal, albeit wholly reasonable, considerations and not a business or occupational necessity. We therefore hold that her home for purposes of section 162(a)(2) was New York and that the expenses at issue in this case were not incurred “while away from home.”12
We are not dissuaded from this conclusion by the temporary nature of Mrs. Hantzis’ employment in New York. Mrs. Hantzis argues that the brevity of her stay in New York excepts her from the business exigencies requirement of section 162(a)(2) under a doctrine supposedly enunciated by the Supreme Court in Peurifoy v. Commissioner, 358 U.S. 59, 79 S.Ct. 104, 3 L.Ed.2d 30 (1958) (per curiam).13 The Tax Court [255]*255here held that Boston was the taxpayer’s home because it would have been unreasonable for her to move her residence to New York for only ten weeks. At first glance these contentions may seem to find support in the court decisions holding that, when a taxpayer works for a limited time away from his usual home, section 162(a)(2) allows a deduction for the expense of maintaining a second home so long as the employment is “temporary” and not “indefinite” or “permanent.” See, e. g., Frederick, supra, 603 F.2d at 1294; Six, supra, 450 F.2d at 69; Wright, supra, 304 F.2d at 224-25; Coburn v. Commissioner, 138 F.2d 763, 764-65 (2d Cir. 1943). This test is an elaboration of the requirements under section 162(a)(2) that an expense be incurred due to business exigencies and while away from home. See note 12, supra. Thus it has been said,
“Where a taxpayer reasonably expects to be employed in a location for a substantial or indefinite period of time, the reasonable inference is that his choice of a residence is a personal decision, unrelated to any business necessity. Thus, it is irrelevant how far he travels to work. The normal expectation, however, is that the taxpayer will choose to live near his place of employment. Consequently, when a taxpayer reasonable [sic] expects to be employed in a location for only a short or temporary period of time and travels a considerable distance to the location from his residence, it is unreasonable to assume that his choice of a residence is dictated by personal convenience. The reasonable inference is that he is temporarily making these travels because of a business necessity.”
Frederick, supra, 603 F.2d at 1294-95 (citations omitted).
The temporary employment doctrine does not, however, purport to eliminate any requirement that continued maintenance of a first home have a business justification. We think the rule has no application where the taxpayer has no business connection with his usual place of residence. If no business exigency dictates the location of the taxpayer’s usual residence, then the mere fact of his taking temporary employment elsewhere cannot supply a compelling business reason for continuing to maintain that residence. Only a taxpayer who lives one place, works another and has business ties to both is in the ambiguous situation that the temporary employment doctrine is designed to resolve. In such circumstances, unless his employment away from his usual home is temporary, a court can reasonably assume that the taxpayer has abandoned his business ties to that location and is left with only personal reasons for maintaining a residence there. Where only personal needs require that a travel expense be incurred, however, a taxpayer’s home is defined so as to leave the expense subject to taxation. See supra. Thus, a taxpayer who pursues temporary employment away from the location of his usual residence, but has no business connection with that location, is not “away from home” for purposes of section 162(a)(2). See Cockrell v. Commissioner, 321 F.2d 504, 507 (8th Cir. 1963); Tucker v. Commissioner, 55 T.C. 783, 786-88 (1971).
On this reasoning, the temporary nature of Mrs. Hantzis’ employment in New York does not affect the outcome of her case. She had no business ties to Boston that would bring her within the temporary employment doctrine. By this holding, we do not adopt a rule that “home” in section 162(a)(2) is the equivalent of a taxpayer’s place of business. Nor do we mean to imply that a taxpayer has a “home” for tax purposes only if he is already engaged in a trade or business at a particular location. Though both rules are alluringly determinate, we have already discussed why they offer inadequate expressions of the purposes behind the travel expense deduction. We hold merely that for a taxpayer in Mrs. [256]*256Hantzis’ circumstances to be “away from home in the pursuit of a trade or business,” she must establish the existence of some sort of business relation both to the location she claims as “home” and to the location of her temporary employment sufficient to support a finding that her duplicative expenses are necessitated by business exigencies. This, we believe, is the meaning of the statement in Flowers that “[b]usiness trips are to be identified in relation to business demands and the traveler’s business headquarters.” 326 U.S. at 474, 66 S.Ct. at 254 (emphasis added). On the uncontested facts before us, Mrs. Hantzis had no business relation to Boston; we therefore leave to cases in which the issue is squarely presented the task of elaborating what relation to a place is required under section 162(a)(2) for duplicative living expenses to be deductible.
Reversed.