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Court denies business deductions after taxpayer reports no income

Tracey Yvonne Lucas v. Commissioner. Tax Court Memo. No. 25645-22. Court Opinion.

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Tax Coda
Mar 04, 2026
∙ Paid

You cannot deduct personal household costs as business expenses, and calling informal caregiving a “business” without a profit motive or records will not survive IRS scrutiny.

Holding

The Tax Court disallowed all Schedule C deductions for 2020 and 2021, sustained an unreported IRA distribution for 2021, and upheld §6662(a) accuracy-related penalties in full.

Why It Matters

  • The court treated informal caregiving with no fixed compensation and minimal receipts as a non-business activity.

  • Failure to maintain separate accounts and contemporaneous records was decisive.

  • The court refused to apply the Cohan rule where expenses were unsubstantiated and included listed property subject to §274(d).

  • Accuracy-related penalties were sustained based on both substantial understatement and negligence.

This is a routine application of settled law. The case reinforces basic compliance standards rather than expanding doctrine.

Key Facts

Tracey Yvonne Lucas worked for the Social Security Administration and reported…

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