Allowing a taxpayer who has to travel two blocks from his home on a business trip to take a § 162(a)(2) deduction, but not the taxpayer whose business requires no travel at all, illustrates the inequitable result of a contrary approach. 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. The Court uses statutory interpretation to affirm the Commissioner’s approach. First, the Court notes that “traveling” implies being “away from home.” Therefore, a broad interpretation of “away from home” would make the phrase redundant. In addition, the Court observes that the statute groups “meals and lodging” together, suggesting Congress’ intent to allow a deduction for the cost of meals only where the business traveler has to pay for lodging as well. Finally, the Court notes that even if alternatives to this bright-line rule are available, it is not the Court’s role to fashion a new rule. “In this area of limitless factual variations, ‘it is the province of Congress and the Commissioner, not the courts, to make the appropriate adjustments.’” Justices Douglas, Black and Fortas dissented on the ground that the phrase “while away from home” goes to geography and not time. The dissent argued that the majority’s approach of interpreting the phrase as “overnight” incorrectly switches the focus to a time element. Significance of the decision The Court affirmed the Commissioner’s interpretation of the “away from home” requirement of § 162(a)(2). By doing so, the Court chose to retain a bright-line rule instead of a case-by-case approach — thereby avoiding uncertainty and excessive litigation. 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. See also Commissioner v. Kowalski - A 1977 Supreme Court decision on the taxability of employer provided meals. List of United States Supreme Court cases, volume 389 References External links United States Supreme Court cases United States Supreme Court cases of the Warren Court United States taxation and revenue case law 1967 in United States case law Food law