“ Resolution of this case as presented to us turns, therefore, upon a narrow question of fact-Was the petitioners' employment 'temporary' or 'indefinite'? The Tax Court, stating that 'each case must be decided upon the basis of its own facts and circumstances,' 27 T.C. at page 157, found that their employment was temporary. The Court of Appeals, also recognizing that the question was 'one of fact,' held that on the record the Tax Court's finding of temporary employment was 'clearly erroneous.' 254 F.2d at page 487. ”

“ The petitioners were employed as construction workers at a site in Kinston, North Carolina, for continuous periods of 20 1/2 months, 12 1/2 months, and 8 1/2 months, respectively, ending in the year 1953. Each of the petitioners maintained a permanent residence elsewhere in North Carolina. In reporting his adjusted gross income for 1953 each petitioner deducted amounts expended for board and lodging at Kinston during the period of employment there, and for transportation from Kinston to his permanent residence upon leaving that employment. ”

“ The issue is whether the amounts in question constituted allowable deductions under § 23 (a) (1) (A) . Generally, a taxpayer is entitled to deduct unreimbursed travel expenses under this subsection only when they are required by 'the exigencies of business.' Commissioner of Internal Revenue v. ”