It’s a well-worn (some readers might say worn out) jibe of mine: lawyers can’t add, and Tax Court judges won’t add. But that’s not so for Judge Elizabeth A. (“Tex”) Copeland, who was a CPA before capping off a stellar career by ascending the Tax Court Bench.

When she sends parties off to a Rule 155 beancount, she has already gotten granular with bank deposit reconstructions, depreciation schedules, and drive-by gasoline deductions.

See Ralph M. Ottuso, T. C. Memo. 2024-91, filed 9/26/24. Ralph sells stoves in Caroga, NY, which features “refreshing rippling waters and its rugged rocky terrain.”

Ralph and his neighbor had an arrangement where Ralph could fill his vehicles at the neighbor’s pump and pay as he went, running a balance. But want of specificity and recordkeeping defeat Ralph’s Section 162 deduction. Ralph can’t show the vehicles are QNUVs, per Section 274(d). The 14K GVW hurdle in Reg. Section §1.274-5(k)(2)(ii) is the problem.

Judge Tex Copeland sorts out a loan and the sales proceeds of a personal use truck, neither of which are taxable, which confused the RA who did the bank deposit reconstruction. And she sorts out and Cohanizes some depreciation deductions.

There’s a bunch concessions (hi, Judge Holmes) , so the Rule 155 beancount is necessary, but it shouldn’t take long.