On September 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Franklin v. Commissioner (T.C. Memo. 2020-127). The primary issues before the court in Franklin v. Commissioner were whether the petitioner was entitled to meal, entertainment, and travel expense deductions and whether the petitioner was entitled to deduct certain business losses. Creating Substantiation in Franklin v. Commissioner The petitioner was in the real estate investment consulting business, which appears to be