In my long and checkered career I never heard a client tell me that when I asked how s/he had calculated or derived some figure. But ex Tax Court semper aliquid novi, as Aristotle (or Pliny the Elder, or whoever) remarked never.

STJ Diana L (“The Taxpayer’s Friend”) Leyden has an off-the-bencher to prove the foregoing. Fwazi Nona, Docket No. 6514-20S, filed 4/7/20, “…has a bachelor’s degree in accounting, with a minor in finance, and is currently employed as an IRS revenue agent.” Transcript, at p. 5.

That’s someone who does audits.

Fwazi claims $10K of Sched A deductions, and Sched C other expenses of $500; (b) travel expenses of $600; (c) taxes and licenses expenses of $200; (d) supplies expenses of $250; (e) office expenses of $700; (f) legal and professional services expenses of $250; (g) insurance (other than health) expenses of $600; (h) car and truck expenses of $12,156; and (i) advertising expenses of $500; and a Schedule D loss of $3,000.” Transcript, at pp. 4-5.

And how does Fwazi come up with these numbers?

“When petitioner was questioned as to how he came up with the dollar amounts for his claimed deductions his response was ‘I guessed.’ He did not track his expenses and did not provide the Court with any evidence to substantiate his claimed deductions. Petitioner also acknowledged that these expenses he claimed as deductions under Schedule C were in fact expenses he incurred as an employee and should have been claimed on Schedule A. Either way petitioner did not substantiate any of his claimed deductions and thus, the Court sustains respondent’s proposed disallowance of these expenses.” Transcript, at p. 8.

Fwazi, you made my day.