That’s ex-CSTJ Lewis (“Nom d’un nom d’un nom!”) Carluzzo’s characterization of the advice of their “old and sick” tax preparer when he told Ehimwenma E. Aimiuwu and Kehinde F. Aimiuwu, T. C. Sum. Op. 2026-7, filed 8/10/26 to “deduct the corporate expenses [of their C Corp] on the [individual] return because [C Corp.] had no income during [year at issue].” T. C. Sum. Op. 2026-7, at p. 2.

Eh and Ke fold all but a $49K charitable deduction which they want to move to their Sched A from the Sched C they filed.

Except.

“Petitioners now argue that the donation deduction claimed on the Schedule C should have been claimed as an itemized deduction on the Schedule A. However, they have presented no written evidence that satisfies the statutory scheme that permits such deductions. Nor have they presented anything that would support a finding that the donee is described in section 170(c).

“Regardless of how the donation deduction should have been taken into account in the computation of petitioners’ … federal income tax liability, it is their burden to establish their entitlement to it. Offering only petitioner’s testimony on the point, they have failed to do so. Respondent’s disallowance of the donation deduction is sustained.” T. C. Sum. Op. 2026-7. at p. 3.

As Eh was a college professor with several postgraduate degree during year at issue, and Ke was an information technology professional (T. C. Sum. Op. 2026-7, at p. 2), they would have run badly in the Section 6662(a) accuracy chops stakes, but for IRS folding those and the Section 6651(a)(1) add-on. T. C. Sum. Op 7, at p. 1, footnote 2.