Liljeberg v. Comm'r of Internal Revenue

Rogers, Circuit Judge:

This is an appeal from the decision of the Tax Court denying a deduction on income earned by three foreign nationals who participated in the State Department's Summer Work Travel Program in 2012. The Internal Revenue Service denied appellants' claimed tax deduction for travel and living expenses incurred "while away from home in the pursuit of a trade or business," 26 U.S.C. § 162 (a)(2). The Tax Court affirmed because appellants' travel and living expenses were not so incurred but arose from a personal choice to participate in the Summer Work Travel Program rather than…