Safaryan v. Commissioner T.C. Memo. 2021-138
On December 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Safaryan v. Commissioner (T.C. Memo. 2021-138). The primary issue presented in Safaryan was whether the petitioners were entitled to deduct certain Schedule C expenses for car and truck expenses, travel expenses, and “other” expenses. Held: Not so much. Background to Safaryan v. Commissioner In 2012 or 2013 the petitioner-husband purchased 10 acres of property in Newberry Springs, California. The property was in the middle of the Mojave Desert, approximately 1 mile away from any road and 120 miles away from petitioners’ residence. The petitioner-husband purchased the property with the intent of developing its natural resources, making it accessible by road, procuring a certification for organic farming, dividing it into parcels, and then renting the parcels to farmers. He called this venture “Paradise Acres.” The petitioner-husband created a business plan, which first required him to construct…



