On May 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Larkin v. Commissioner (T.C. Memo. 2020-70). The underlying issue before the court in Larkin v. Commissioner was whether the petitioners provided substantial, credible evidence to support their deductions claimed on their returns for the years at issue. Although there are a number of sub-issues, the entry of arguments and evidence into the record through pleading and briefs is the primary