U.S. Tax Court Memorandum Decision Upholds IRS Decision, Denies Taxpayer’s Business Expense Deductions

The U.S. Tax Court, in a memorandum decision, held that the taxpayer was not entitled to deduct expenses reported on Schedules C and was liable for accuracy-related penalties, sustaining the IRS’s determinations. Taxpayer, an individual, reported a home healthcare business on her tax returns for the years at issue, claiming various business expenses but reporting no gross receipts. The business involved looking after an acquaintance’s daughter, for which the taxpayer received minimal, unreported payments. The taxpayer did not maintain separate business records or accounts. The court held that the taxpayer’s activities did not constitute a trade or business under IRC ...