The above is the title of a book written by researcher-writer Debra Lea Jones-Mazotti, who appears in Robert Dean Mazotti and Debra Lea Jones-Mazotti, T. C. Memo. 2024-75, filed 7/25/24. According to Judge Courtney D. (“CD”) Jones, “Filthy Fingers was included as an exhibit, and the document identified as a book appears to be approximately two pages long.” T. C. Memo. 2024-75, at p. 3.

Ms. Jones-Mazotti testified extensively on the trial about her thirty (count ’em, thirty) years of researching and writing.

“During the tax years at issue, Ms. Jones-Mazotti took numerous trips, expenses for which were included on her Schedules C as deductions claimed for writer-researcher activities.

“During these trips to various locations—such as California and Florida—she purportedly conducted research for books, articles, and scavenger hunts she was creating. She also traveled to Hawaii in 2020 to allegedly study macadamia nuts for her books. Some members of her family, including her husband and daughter, typically traveled with her on these trips. During these trips, Ms. Jones-Mazotti purportedly took photos of fruits, vegetables, and trees for her writer-researcher activities.

“Ms. Jones-Mazotti testified that she traveled to California and to Disney World to research a family trivia game she wanted to write. However, Ms. Jones-Mazotti also admitted that the trip to Disney World coincided with a high school football function for one of her sons, where he played a football game.” T. C. Memo. 2024-75, at p. 5.

Obviously, it’s “goofy regulation” time. That’s Reg. Section 1.183-2(b), the hobby loss checklist. The scorecard: “The record shows clearly that the Mazottis reported $1,045 in gross receipts and $187,012 in expenses, resulting in a total loss of $185,967 over the three tax years at issue.” T. C. Memo. 2024-75, at pp. 14-15.

Ms. Jones-Mazotti’s trial testimony was also less than convincing to Judge CD Jones. “Ms. Jones-Mazotti testified that she has spent her entire life writing. However, the record is devoid of evidence as to precisely how much time she spent on the writer-researcher activities during the tax years at issue. Further, although Ms. Jones-Mazotti testified inconsistently about the work she produced during the tax years at issue, we found her testimony self-serving. For example, Ms. Jones-Mazotti stated that she traveled extensively to conduct research for her books. But the record reflects that Ms. Jones-Mazotti reported expenses from personal vacations as business expenses on her tax returns and used her interest in writing to justify these claimed deductions.” T. C. Memo. 2024-75, at p. 13.

With neither profit and loss statement, nor much substantiation, testimony counts for much.

“Ms. Jones-Mazotti did not keep formal books and records related to her purported writer-researcher expenses. And she has never run a profit-and-loss statement. Moreover, the Mazottis claimed deductions for personal expenses such as family vacations, clothing, food, home improvements, and vehicle maintenance and repair costs. When pressed about the nature of the deductions, Ms. Jones-Mazotti was evasive and often unable to explain how these personal deductions related to her purported writer-researcher business activities. A reasonable and prudent person would know that personal expenses may not be deducted under the guise of business expenses.” T. C. Memo. 2024-75, at p. 17.