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Regulatory Ethics
Kentucky Professional Ethics

Joseph Helstrom, CPA

QAS Self-Study
Credits: 2 $58.00
Accounting
World’s Liveliest Accounting Update 2026

Jeff Sailor, CPA

Webcast
Credits: 4 $196.00
Accounting
SSARS Update and Review 2026

Jeff Sailor, CPA

Webcast
Credits: 3 $147.00
Regulatory Ethics
Michigan Professional Ethics

Joseph Helstrom, CPA

QAS Self-Study
Credits: 2 $58.00
Regulatory Ethics
Professional Ethics for Massachusetts CPAs

Joseph Helstrom, CPA

QAS Self-Study
Credits: 4 $116.00
Auditing
World’s Liveliest Auditing Update 2026

Jeff Sailor, CPA

Webcast
Credits: 3 $147.00
Accounting
Focus On Fraud 2026

Jeff Sailor, CPA

Webcast
Credits: 1 $49.00
Regulatory Ethics
CPA Ethics: Integrity, Objectivity & Independence

Delta CPE LLC

QAS Self-Study
Credits: 2 $58.00
Accounting
Nonprofit Accounting

Steven M. Bragg, CPA

QAS Self-Study
Credits: 16 $384.00
Accounting
Accounting & Reporting for Crypto Assets

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 1 $29.00
Regulatory Ethics
Dealing with Frivolous Tax Arguments

Steven M. Bragg, CPA

QAS Self-Study
Credits: 2 $58.00
Business Law
Sexual Harassment Awareness

Delta CPE LLC

QAS Self-Study
Credits: 1 $29.00
Accounting
Accounting for Software – Internal Use & External Sales

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 2 $58.00
Accounting
How to Account for Internal-Use Software Arrangements

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 1 $29.00
Accounting
Overview of the Statement of Cash Flows

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 1 $29.00
Accounting
What You Need to Know About Cash Flow

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 2 $58.00
Finance
The Investor Relations Guidebook

Steven M. Bragg, CPA

QAS Self-Study
Credits: 15 $375.00
Accounting
True Sale Opinions: What You and Your Auditor Needs to Consider

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 1 $29.00
Personal Development
Seven Habits of Effective CEOs

Steven M. Bragg, CPA

QAS Self-Study
Credits: 1 $29.00
Computer Software & Applications
Working with Downloaded Data –Manipulating Text and Numbers

Joseph Helstrom, CPA

QAS Self-Study
Credits: 1 $29.00
Auditing
Cybersecurity Risk Management Trends

Jennifer F. Louis, CPA

Webcast
Credits: 2 $98.00
Auditing
Sampling – Avoiding Common Mistakes on Financial Statement and Compliance Audits

Jennifer F. Louis, CPA

Webcast
Credits: 2 $98.00
Accounting
Accounting for Breweries

Steven M. Bragg, CPA

QAS Self-Study
Credits: 2 $58.00
Accounting
Construction Accounting

Steven M. Bragg, CPA

QAS Self-Study
Credits: 11 $308.00
Accounting
Do I Have A Lease?

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 1 $29.00
Accounting
Principles of Financial Statement Presentations

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 4 $116.00
Accounting
Evaluating and Properly Disclosing FASB Accounting Standard Updates (ASUs)

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 1 $29.00
Accounting
Accounting for Held for Sale Assets

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 2 $58.00
Accounting
Supplier Finance Programs – What You Need to Disclose

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 1 $29.00
Accounting
Ongoing SQM Activities

Jeff Sailor, CPA

Webcast
Credits: 1 $49.00
Accounting
Accounting for Inventory

Jeff Sailor, CPA

Webcast
Credits: 2 $98.00
Accounting
Fair Value Measurements

Jeff Sailor, CPA

Webcast
Credits: 2 $98.00
Taxes
Estate Planning

Danny Santucci, JD

QAS Self-Study
Credits: 2 $58.00
Taxes
Passthrough Business Deduction

Danny Santucci, JD

QAS Self-Study
Credits: 2 $58.00
Auditing
Auditing Red Flags

Steven M. Bragg, CPA

QAS Self-Study
Credits: 8 $232.00
Accounting
Detailed Overview of the Held for Sale Classification Criteria

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 1 $29.00
Accounting
Optimize Cash Flow Through Receivables Factoring

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 2 $58.00
Accounting
SEC Pay Versus Performance Disclosures- What You Need to Know

Kelen Camehl, CPA, MBA

QAS Self-Study
Credits: 1 $29.00
Taxes
Fast Track Retirement Planning

Danny Santucci, JD

QAS Self-Study
Credits: 2 $58.00
Regulatory Ethics
South Carolina Regulatory Ethics

Joseph Helstrom, CPA

QAS Self-Study
Credits: 2 $58.00
Auditing
How to Audit Procurement

Steven M. Bragg, CPA

QAS Self-Study
Credits: 1 $29.00
Auditing
Fraud Schemes

Steven M. Bragg, CPA

QAS Self-Study
Credits: 3 $87.00
Taxes
IRA Withdrawals

Mary Kay Foss, CPA

Webcast
Credits: 2 $147.00
Taxes
Final 1040/First 1041

Mary Kay Foss, CPA

Webcast
Credits: 3 $147.00
Accounting
Private Company FASB GAAP Alternatives

Jennifer F. Louis, CPA

Webcast
Credits: 2 $98.00
Accounting
Health Care Accounting

Steven M. Bragg, CPA

QAS Self-Study
Credits: 12 $336.00
Regulatory Ethics
2026 Virginia-Approved Professional Ethical Considerations for CPAs

Jennifer F. Louis, CPA

Webcast
Credits: 2 $98.00
Auditing
Quality Management Standards Post-Implementation

Jennifer F. Louis, CPA

Webcast
Credits: 2 $98.00

Learn More

February 11, 2025

John K. Pak, et al v. Comm., TCM 2024-86

Cohan Works for Contract Labor and Depreciation (John K. Pak, et al v. Comm., TCM 2024-86) John Pak operated a high-end Japanese restaurant inside a leased space in a shopping mall in Gulf Shores, Alabama. The location was undeveloped and substantial custom build-out improvements were made to create the restaurant with hibachi grills, a 25-foot sushi bar and 16-foot martini bar. Mr. Pak testified that he spent over $1.5 million on the build-out and equipment but could not provide any records to substantiate the amounts claimed at trial – 12 years after the improvements had been made. He also claimed …

February 11, 2025

Christopher R. Pangelina v. Comm., TCM 2024-5

Tile Contractor Unable to Shore Up Deductions Without Proper Substantiation (Christopher R. Pangelina v. Comm., TCM 2024-5) Christopher Pangelina filed each of his 2010 through 2017 income tax returns between one and six years late. Although 2017 was technically a substitute-for-return prepared by the IRS, Mr. Pangelina did provide a copy of an unsigned 2017 tax return two days before the first scheduled trial date on Feb. 1, 2021. Each of his returns was prepared by a paid preparer. In an examination of the returns, the IRS had disallowed the following expenses:YearDescriptionAmounts2010Other Deduction$100,2462011All deductions allowed$02012Rent & Wages$18,259 & $34,7912013Interest & …

February 11, 2025

Paul Anthony Steward v. Comm., TCS 2024-3

Tile Contractor Unable to Shore Up Deductions Without Proper Substantiation (Christopher R. Pangelina v. Comm., TCM 2024-5) In 2018 and 2019, Paul Anthony Steward was a performing musician. He claimed auto expenses for driving his car from his home to various venues where he performed with his band. He introduced an after-the-fact mileage log and documentation of royalties he collected for his performances. He claimed that many of his records were destroyed in a fire. The IRS had allowed a portion of the claimed auto expenses, and even more in a stipulation after trial. Mr. Steward also claimed $19,402 for …

February 11, 2025

Jesse Alvarado and Estate of Maria De Lourdes Velasques v. Comm., TCM 2024-1)

Used Car Salesman Sells Judge on Cohan Rule (Jesse Alvarado and Estate of Maria De Lourdes Velasques v. Comm., TCM 2024-1)) After 25 years as a commercial lender at Comerica Bank, Mr. Alvarado opened South Bay Autos, a used car business, preparing a few tax returns on the side. South Bay relied heavily on credit, both for the acquisition of inventory and for the sale of vehicles to customers. South Bay purchased vehicles at car auctions using credit with terms that required repayment in 45 days before having to pay high interest charges. Vehicles were generally sold on credit, with …

February 11, 2025

Karim Gobran and Ashley Smith-Gorbran v. Comm., T.C. Summary 2023-24

Multiple Years at Same Job Location is Not Temporary (Joseph & Ashley Ledbetter v. Comm., TC Summary 2023-19) Mr. Ledbetter was a union craft sheet metal worker from 2000 through the years at issue – 2015 and 2016. He received all of his work assignments through his union. The work assignments he received were with a contactor to the Tennessee Valley Authority (TVA). The contractor did not hire sheet metal workers on a permanent basis. The length of the assignments varied with the size of projects and availability of funds. Mr. Ledbetter worked for the same contractor at TVA for …

February 11, 2025

William French Anderson et al v. Comm., CA-10 No. 23-9002, May 17, 2024

Second Opinion: Appellate Court Confirms Tax Court Diagnosis – Doctor’s Legal Fees Not Deductible (William French Anderson et al v. Comm., CA-10 No. 23-9002, May 17, 2024) William French Anderson, considered to be the “father of gene therapy”, was denied deductions for legal expenses of $292,175 and $68,120 on his 2013 and 2014 income tax returns, respectively. In 2006 he was convicted of sexual abuse of a minor (the daughter of his senior lab scientist and business partner) and sentenced to 14 years in prison. He filed numerous appeals, all of which were denied. In the Tax Court, Dr. Anderson …

February 11, 2025

Mylan, Inc. & Subsidiaries v. Commissioner of Internal Revenue, 156 T.C. No. 10, aff’d CA-3 Nos. 22-1193, 21-1194 and 22-1195 (July 27, 2023)

Legal Fees Incurred by Generic Drug Manufacturer Not Required to be Capitalized (Mylan, Inc. & Subsidiaries v. Commissioner of Internal Revenue, 156 T.C. No. 10, aff’d CA-3 Nos. 22-1193, 21-1194 and 22-1195 (July 27, 2023)) Generally, legal expenses incurred in defense of a patent or in a patent infringement action when creating a new product would be required to be capitalized as part of the cost of the asset. Treas. Reg. §1.263(a)-(4)(b)(1)(v) requires that a taxpayer capitalize “an amount paid to facilitate” an acquisition or creation of an intangible.Mylan brought generic drugs to market using and FDA process called Abbreviated …

February 11, 2025

Edwin L. Gage and Elaine R. Gage v. Comm., TCM 2023-47

Settlement Payment Given to Attorney Not Deductible Until Delivered (Edwin L. Gage and Elaine R. Gage v. Comm., TCM 2023-47) The Gages had a protracted dispute with the Department of Housing and Urban Development (HUD). They reached a settlement in 2012 requiring them to pay $875,000 to HUD. In December 2012, the Gages purchased a cashier’s check for $875,000 and gave it to their attorney. Their attorney contacted the HUD attorney and offered the payment, but the HUD attorney would not accept the check until the settlement was finally approved. The Gages’ lawyer held the check. The settlement was approved …

February 11, 2025

James Avery v. Comm., TCM 2023-18

Race Car Driving is Not Advertising for Attorney (James Avery v. Comm., TCM 2023-18) Avery was an attorney who got involved in showing collector cars as a way to meet potential clients. He later moved on to car racing by attending a racing school, purchasing and rebuilding a 2000 Dodge Viper.Avery claimed racing-related expenses of $355,000 as advertising for his law practice over six years (all in even dollar amounts – $50,000 for both 2008 and 2009; $60,000 for both 2010 and 2011; $65,000 for 2012; and $70,000 for 2013). Avery’s name appeared on a small area above the driver’s …

February 11, 2025

Noah Schmerling and Susana Schmerling v. Comm., TCS 2023-14

Car Salesman’s “Other Income” was Not Separate Trade or Business (Noah Schmerling and Susana Schmerling v. Comm., TCS 2023-14) Noah Schmerling was a car salesman who received W-2 wage compensation from his BMW dealership employer. He also received income on Forms 1099-MISC from BMW for participation in their Performance Bonus Program and from Devex for sales of extended warranty service contracts. Noah reported the 1099-MISC amounts as income on Schedule C and claimed expenses related to the income. The Court determined that the 1099-MISC amounts received did not constitute a business separate and apart from his employment as a car …

February 11, 2025

Thomas Laronn Mitchell v. Comm., TCS 2023-9

No Records Plus Conflicting Records Plus Self-Serving Testimony Equals No Deductions (Thomas Laronn Mitchell v. Comm., TCS 2023-9) The Tax Court just could not bring itself to allow any deductions in this case. You will probably agree. Mr. Mitchell attempted to substantiate $22,499 in car and truck expenses with a mileage log showing 81,186 business miles in 2018. State inspection records covering a 12-month period that included most of 2018 revealed a mileage difference of only 21,816 miles. The mileage log also had some date issues: while driving in Dallas, TX he submitted a hotel receipt for a stay in …

February 11, 2025

Russell E. Barrios v. Comm., TCM 2023-32

Non-Filer Cannot Rely on Profit and Loss Statement to Substantiate Expenses (Russell E. Barrios v. Comm., TCM 2023-32) Mr. Barrios failed to file his 2011 tax return. The IRS prepared a substitute for return under §6020(b) and a notice of deficiency was issues. Barrios presented a CPA-prepared Form 1040 and a profit and loss statement at trial in an effort to substantiate more expenses than the IRS was allowing. He did not provide any source documents and relied upon testimony from his CPA, who claimed to have verified the amount on the profit and loss statement. The CPA testified that …

February 11, 2025

Mohamed Elbasha v. Comm., TCM 2022-001

Home Office Denied for ER Doctor (Mohamed Elbasha v. Comm., TCM 2022-001) Mohamed Elbasha worked as a contract emergency room doctor at Murray Medical Center in Chatsworth, Georgia. Dr. Elbasha testified that he had no office at Murray Medical Center and so exclusively used one room in, or 50% of, his condominium to do paperwork related to his emergency room duties.Dr. Elbasha deducted $18,000 for a Schedule C rent/lease—other business property expense on his 2008 Form 1040. This deduction related to the use of his condominium as a home office. He provided a chart listing the hours each month he …

February 11, 2025

Terence and Janet Keating v. Comm., TCM 2024-2

Insurance Premiums Must be for Insurance (Terence and Janet Keating v. Comm., TCM 2024-2) Terence and Janet Keating were shareholders of Risk Management Strategies, Inc. (RMS), an S corporation whose business was being an employer for its clients, which were primarily banks administering special needs trusts. RMS assumed the employer liability resulting from the employment of caregivers who worked for special needs trusts, handled payroll, and generally carried out the responsibilities of being an employer to caregivers and other employees that would have otherwise fallen on its clients. For each year at issue, RMS reported incurring approximately $1.2 million of …

February 11, 2025

Sunil S. Patel and Laurie McAnally- Patel v. Comm., TCM 2024-34

Circular Flow of Funds Flushes Claim of Insurance Expense (Sunil S. Patel and Laurie McAnally- Patel v. Comm., TCM 2024-34) The Patels owned an eye surgery practice, Ophthalmology Specialists of Texas (OST) and two companies used to conduct clinical research trials on experimental drugs for retina diseases: Integrated Clinical Research, LLC (ICR) and Strategic Clinical Research Group, LLC (SCR). The Patels also formed West Texas Hospital with other doctors, in part, so Dr. Patel (Sunil) would not have to wait for operating rooms for his patients. After suffering substantial losses related to a patient death at the hospital, the Patels …

February 11, 2025

Patricia Chappell v. Comm., TCS 2024-2

GPS Tracker Doesn’t Work Alone to Get Deduction for Tax Preparer (Patricia Chappell v. Comm., TCS 2024-2) Patrica Chappell used MileIQ to track location from March 23 and Dec. 15, 2015. From the app, she entered whether trips were business or personal. MileIQ summarized Ms. Chappell’s tracking information and provided a log that could be used to help substantiate her business miles driven during the year. Ms. Chappell’s driver’s license was suspended for about six months in the middle of 2015. During that time, she used a driver. In a close examination of her records, there were inconsistencies in dates …

February 11, 2025

Maribel Gonzalez v. Comm., TCS 2022-13

Clothing Business Schedule C Expenses Including Travel & Auto Allowed (Maribel Gonzalez v. Comm., TCS 2022-13) Maribel Gonzalez started a clothing design business in Los Angeles as a wholesaler, designing children’s clothing, and hired a patternmaker in Los Angeles. Ms. Gonzales lived and worked in Palo Alto. She drove from Palo Alto to Los Angeles approximately every other weekend to review the patternmaker’s work and deliver supplies. While her records were limited, she did have an excel spreadsheet travel log, indicating the purpose of the travel and estimating the costs of the travel. She also had car maintenance receipts substantiating …

February 11, 2025

Joseph William Sherman v. Comm., TCM 2023-63

ER Doctor’s Film and Music Activity Not Engaged in for Profit (Joseph William Sherman v. Comm., TCM 2023-63) “Doctor, doctor, please. Oh, the mess I’m in.” UFO got it right in this case. Joseph Sherman was an emergency room doctor with a side hustle “film production company that combines music and film.” In addition to working about 120 hours per month as a physician, Dr. Sherman “guesstimated” that he also spent 200 to 300 hours per month on his activity – Songswell. For 2015, Songswell generated no revenue and reported $104,758 in expenses. He was unable to produce anything other …

February 11, 2025

Leslyn Jo Carson & Craig Carson, Docket 23086-21S (March 22, 2023)

IRS Misinterpreted Activity – A Farm is Not a Rodeo (Leslyn Jo Carson & Craig Carson, Docket 23086-21S (March 22, 2023)) The Carsons deducted losses for several years on a Schedule F “livestock” activity. In 2017, Schedule F reported gross income of $2,741 in rodeo competition winnings and total expenses of $128,990. In 2018 Schedule F reported gross income of $8,063 ($1,867 compensation for the Carsons’ children’s labor and $6,196 in rodeo competition winnings) and total expenses of $133,929. The IRS proposed to treat the Schedule F activity as not engaged in for profit.Leslyn Jo Carson’s mother owned a ranch …

February 11, 2025

Robert Dean Mazotti and Debra Lea Jones-Mazotti v. Comm., TCM 2024-75

One and Two-Page Books do not an Author Make (Robert Dean Mazotti and Debra Lea Jones-Mazotti v. Comm., TCM 2024-75) Debra Jones-Mazotti claimed to be a for-profit writer-researcher. The IRS classified her activity as not for profit in tax years 2018, 2019, and 2020. She had been claiming expenses as a writer-researcher for three decades before recording a profitable year in 2022. She traveled for her writing to California, Florida, and Hawaii. Her husband or daughter generally traveled with her. Trips to California and Disney World (Florida) were purportedly research on a family trivia game she wanted to write. On …

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Western CPE LLC

Kentucky Professional Ethics

World’s Liveliest Accounting Update 2026

SSARS Update and Review 2026

Michigan Professional Ethics

Professional Ethics for Massachusetts CPAs

World’s Liveliest Auditing Update 2026

Focus On Fraud 2026

CPA Ethics: Integrity, Objectivity & Independence

Nonprofit Accounting

Accounting & Reporting for Crypto Assets

Dealing with Frivolous Tax Arguments

Sexual Harassment Awareness

Accounting for Software – Internal Use & External Sales

How to Account for Internal-Use Software Arrangements

Overview of the Statement of Cash Flows

What You Need to Know About Cash Flow

The Investor Relations Guidebook

True Sale Opinions: What You and Your Auditor Needs to Consider

Seven Habits of Effective CEOs

Working with Downloaded Data –Manipulating Text and Numbers

Cybersecurity Risk Management Trends

Sampling – Avoiding Common Mistakes on Financial Statement and Compliance Audits

Accounting for Breweries

Construction Accounting

Do I Have A Lease?

Principles of Financial Statement Presentations

Evaluating and Properly Disclosing FASB Accounting Standard Updates (ASUs)

Accounting for Held for Sale Assets

Supplier Finance Programs – What You Need to Disclose

Ongoing SQM Activities

Accounting for Inventory

Fair Value Measurements

Estate Planning

Passthrough Business Deduction

Auditing Red Flags

Detailed Overview of the Held for Sale Classification Criteria

Optimize Cash Flow Through Receivables Factoring

SEC Pay Versus Performance Disclosures- What You Need to Know

Fast Track Retirement Planning

South Carolina Regulatory Ethics

How to Audit Procurement

Fraud Schemes

IRA Withdrawals

Final 1040/First 1041

Private Company FASB GAAP Alternatives

Health Care Accounting

2026 Virginia-Approved Professional Ethical Considerations for CPAs

Quality Management Standards Post-Implementation

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