Key legal question
Whether a loss certificate arising from unbooked self-employment income is deductible as a business loss in 2016.
Extracted holding
No. A loss can be deducted only if the underlying income had previously been recorded and taxed; uncollected fees that were never booked cannot be deducted again as a loss.
Extracted reasoning
The taxpayer admitted that the amount was not booked and did not need to be taxed because it consisted of unpaid fees. Allowing the deduction would lead to double consideration. The requested evidentiary hearings could not change that result.