Adler v. Commissioner T.C. Memo. 2021-56
On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Adler v. Commissioner (T.C. Memo. 2021-56). The primary issue presented in Adler v. Commissioner was whether the petitioner was entitled to deduct business expenses for 2016 and 2017 (the years in issue). Adler v. Commissioner In Short The petitioner was a consultant for an entertainment company in Los Angeles. He incurred business-related expenses, including travel expenses, and he reported these expenses on his Schedule C in 2017. The trouble was that the entertainment company was in the habit of reimbursing the petitioner for his expenses, and the CFO testified that this was the company’s practice. The petitioner was not able to substantiate his travel expenses, and the Tax Court could not apply the Cohan Rule, as travel expenses fall under the IRC § 274 carveout of Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.…
