Suleiman Sami, T. C. Memo. 2026-69, filed 8/18/26, claims he is one such, but despite his two (count ’em, two) accounting degrees he cannot keep enough records to cause Judge Elizabeth A. (“Tex”) Copeland to allow a bunch deductions (hi, Judge Holmes). COGS for his ticket scalping business fail, but he does get Cohan treatment for the two (count ’em, two) passenger vehicles he runs in his unlicensed rideshare operation because he kept all the trip slips and his credit card and EZpass statements provide some basis for expenses.

As for influencing, he shows no income for years at issue, although Judge Tex Copeland shows how influencers make money (T. C. Memo. 2026-69, at pp. 4-5). Sami’s costly appearances at celebrity events, which he puts up on his social media, don’t qualify as business. Dropping a pass from Tom Brady and missing a serve from John McEnroe are just too much fun, even if you put them on your page. When he claims what he pays to attend big-ticket charity events are contributions, that founders on “no goods or services.”

Long before there were “influencers,” I missed three (count ’em, three) serves from Ray Ruffles, who won the Wimbledon mixed doubles that year; can’t say it was fun.

Sami did all his own Exam and pre-trial, but brought in The Jersey Boys and friends to try the case. Wise move.