Two Sum. Ops., but each has a twist.

Gregory A. Rodrigues, T. C. Sum. Op. 2026-4, filed 6/29/26, is the usual story of insufficiently-documented Section 274 travel, meals, and entertainment expenses for his real estate operations with his Harvard B-School buddies.  

CSTJ Zachary S. (“High Rise”) Fried: “The trips included travel with petitioner’s business school friends and with Ms. George, with whom petitioner shares a residence and a child. Although petitioner maintains that Ms. George accompanied him in her capacity as his attorney, the record contains no documentary evidence of an attorney-client relationship, and under the circumstances, we reject that assertion.” T. C. Sum. Op. 4, at p. 7. 

Seems the reverse of the usual situation.

He does get a grand or two of business expenses.

Edmund Ha, T. C. Sum. Op. 2026-5, filed 6/29/26, is an even greater traveler, but his fiduciary duty to his clients (he’s a high-priced international broker) prevents him from doing the Section 274 number with his preparer.  This costs him deductions and chops.

But STJ Peter (“HB”) Panuthos bows to Cohan to allow Edmund his home office expense deduction.

“In support petitioner submitted a log, credit card statements, a floor plan of his apartment, and a receipt for eight rental payments at his home address…. 

“Petitioner’s log lists the expense, the amount, and the purpose of each item reported. Petitioner testified credibly as to his business as a real estate agent, and the Court is satisfied that petitioner operated exclusively out of his home, incurred the listed expenses, and that those expenses had a business purpose. Consequently, petitioner has provided sufficient evidence for the Court to rely on the Cohan rule to estimate petitioner’s home office expenses. 

“Accordingly, the Court concludes that petitioner is entitled to a deduction for his home office and related expenses.” T. C. Sum. Op. 2026-5, at p. 7.

It’s up to the Rule 155 beancount to see how heavily STJ Panuthos bears on Edmund for inexactitude of his own making.