On January 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Christensen v. Commissioner (T.C. Memo. 2020-14). The sole issue presented in Christensen v. Commissioner was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a). Deductibility of Expenses in General as explained by Christensen v. Commissioner Because deductions are a “matter of legislative grace,” taxpayers bear the burden of establishing their entitlement thereto. Tax Court Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). The taxpayer’s burden is met by substantiating the amount and purpose of each expense that the taxpayer claims as a deduction. Hradesky v. Commissioner, 65 T.C. 87, 89 (1975), aff’d per curiam, 540 F.2d 821 (5th Cir. 1976). As a part of satisfying this burden, taxpayers must maintain sufficient records. IRC § 6001; Treas. Reg. § 1.6001-1(a). No records, no substantiation. Generally,…