U.S. Tax Court Upholds Deficiency Determination, Denies Business Deductions for Lack of Substantiation

The U.S. Tax Court held that a taxpayer was not entitled to claimed business expense deductions and was liable for additions to tax, sustaining the IRS’s deficiency determination. Taxpayer, an engineering professional, worked multiple jobs in 2018, including a contract position with a technology company that required him to stay near the office on weekdays while commuting to his residence on weekends. Taxpayer did not file federal income tax returns for 2017, 2018, or 2019, prompting the IRS to prepare a substitute for return using only information from one employer and determining deficiencies plus additions to tax under IRC §6651(a)(1), ...