
The IRS Doesn't Have to Prove You Lied — It Just Has to Prove Your Receipts Don't Exist
In Goodwill-Oikerhe v. Commissioner, a tax preparer lost every disputed deduction — dependents, property tax, vehicle expenses, S-corp flow-throughs — and drew a 75% civil fraud penalty under Section 6663, largely because no records existed. Why the Cohan rule couldn't rescue him, and what contemporaneous bookkeeping must capture to survive an audit.









