That’s how Judge Joseph W. Nega finds the testimony in MD M. Rahman & Syeda Momotaz, Docket No. 8286-23, filed 10/13/26. It comes from MD M. explaining his accounting methods.

Unfortunately, it doesn’t provide Judge Nega enough to Cohanize whatever expenses Rahman claims above whatever IRS and he stiped.

 “In his testimony, Mr. Rahman not only insisted that he should prevail entirely on all disputed deduction amounts, but he repeatedly explained petitioners total lack of documentation as a result of the looting of his store on June 1st, 2020, and March 28th, 2021.

“However, his testimony did not explain how then he was able to substantiate all the deductions allowed in the stipulation of settled issues and during the examination but none of the items that now remain at issue. His admission regarding his incomplete bookkeeping and his habit of paying personal expenses from his business account do not bolster his arguments. While his testimony is refreshing, it does not give the Court enough to apply a Cohan analysis.” Transcript, at p.11.