On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn v. Commissioner were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue; (2) whether the petitioners are entitled to theft loss deductions for their tax years 2010 and 2013; and (3) whether the petitioners are liable for the IRC § 6662(a) accuracy-related penalty for each tax year at issue. Background to Littlejohn v. Commissioner It is never a good sign for the petitioner when the Tax Court begins its finding of facts with the observation that not only does petitioner-husband a law degree, but also that the petitioner-husband previously taught law at the Southern California Institute of Law in Santa Barbara. It is likely that the professor did not teach tax law,…