On July 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Simpson v. Commissioner (T.C. Memo. 2020-100). The issue before the court in Simpson v. Commissioner was whether the petitioners were allowed deductions for unreimbursed partnership expenses (2012-2014) and unreimbursed employee business expenses (2014), which deductions were adjusted in the IRS’s amended answer. Background to Simpson v. Commissioner The IRS issued the petitioners a notice of deficiency for tax years 2012, 2013, and 2014. Among other determinations made in that notice, the IRS disallowed the petitioners’ deductions for unreimbursed partnership expenses and unreimbursed employee business expenses. The IRS also disallowed unreimbursed employee business expense deductions for 2012 and 2013, and the some of the unreimbursed partnership expense deductions for 2013 and 2014. The IRS answered the petition, and (for reasons not specified in the opinion) decided to turn the screws on the petitioners even more and…