Edward W. Andrews (plaintiff) was the president and chief executive officer of a pool business in Massachusetts. Because the pool business operated seasonally, Andrews began operating a horse breeding business in the off-season. Eventually, Andrews expanded his operations by establishing horse and pool businesses in Florida. Andrews spent about six months, from January through April and from November through December, in Florida. He spent the remainder of the year in Massachusetts. In an effort to minimize his travel expenses, Andrews purchased a second home in Florida. On his tax return for 1984, Andrews claimed travel expense deductions for all meals and costs related to maintaining his Florida home. The Commissioner (defendant) disallowed the deductions. The Tax Court upheld the disallowance.