Tax Court Again Disallows Unsubstantiated Expenses

In Kyne v. Commissioner, T.C. Summ. Op. 2009-98 (June 25, 2009), the Tax Court has ruled in favor of the IRS disallowing unsubstantiated expenses. We are seeing more and more cases from audit to appeals to the courts where taxpayers are losing, if expenses taken as a deduction cannot be substantiated. It is a good time to remind clients to improve record keeping and make sure documentation exists to prove deductions.