The Tax Court in Brief September 20 – September 24, 2021

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The Tax Court in Brief September 20 – September 24, 2021

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

For a link to our podcast covering the Tax Court in Brief, download here or check out other episodes of The Freeman Law Project.

Tax Court Litigation: The Week of September 20 – September 24, 2021

Tax Court Case:

Daniel Omar Parker and Chantrell Antoine Parker v. Comm’r, No. 13231-19, T.C. Memo 2021-111

September 23, 2021 | Lauber | Dkt. No. 13231-19

Short SummaryThis case analyzes the availability of certain deductions of the taxpayer, namely:  (1) Car and truck expenses; (2) Retirement contributions; (3) Certain unreimbursed employee business expenses claimed as itemized deductions on Schedule A; and (4) the cost of demolishing a structure.

Tax Court Key Issues:

Facts and Primary Holdings

Car and Truck Expenses

Retirement Contributions

Unreimbursed Employee Business Expenses

Demolition Expenses

Key Points of Law:


Car and Truck Expenses

Retirement Contributions

Unreimbursed Business Expenses

Demolition Expenses


Tax Court InsightThe taxpayer’s positions in this case appeared to have been developed only after the IRS made its assessment.  There appears to have been very little planning and documentation on the part of the taxpayers.  Since the burden is on taxpayers to support any deductions claimed, taxpayers must take care to keep solid documentation, especially when dealing with expenses identified in Section 274 that carry a heightened substantiation requirement.

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