Cassandra Tucker and Edward Brodie, T. C. Memo. 2023-87, filed 7/17/23, have plenty of problems, but most arise from Cassandra’s want of records for her fashion lifestyle business, and that’s just more indocumentado.

Judge Tamara Ashford does allow Cassandra the $25K deduction for the extended visit she paid (with goods and models) to a limited access TV channel. Infomercials are advertising. See T. C. Memo. 2023-87, at p. 14.

“Nowadays, advertising through media comes in many different forms, from traditional forms, such as broadcast (i.e., television and radio) and print (i.e., newspapers, magazines, signs, and billboards), to new forms, such as websites, apps, emails, podcasts, blogs, and social networks. We view Ms. Tucker’s appearance promoting [business] on the Hidden Gemz television show as the equivalent of an extended, live television commercial, more along the lines of a traditional form of advertising through media. Furthermore, it is apparent that Ms. Tucker’s primary motive or purpose in appearing on the show was to increase [business]’s visibility and in turn generate sales of [business] products. Thus, on the basis of the record before us, we conclude that the expenses Ms. Tucker incurred by appearing on the show had a reasonably proximate relationship to [business] and Ms. Tucker’s primary motive or purpose for incurring the expenses…; thus, petitioners are entitled to deduct advertising expenses….” (Citations omitted).

Ed ran a rental realty operation with his friend Nassy, and they paid deductible mortgage interest. Problem was, Ed couldn’t prove what he paid. While they were tenants-in-common (presumably fifty-fifty), and while Ed claimed he ran and paid everything, and Nassy was passive, Ed had neither checks nor receipts for what was paid.

“Where a mortgaged property is jointly owned and the co-owners are jointly liable on the mortgage, each owner is entitled to a deduction for the mortgage interest that he or she actually pays out of his own funds.” T. C. Memo. 2023-87, at p. 21. (Citations omitted).

When you’re a partner, be you active or passive, nothing succeeds like paper.