Nikita Andreyevich Krasilnikov v. Commissioner of Revenue.

Massachusetts Appeals Court·Decided July 10, 2026·No. 24-P-0786·Unpublished

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

24-P-786

NIKITA ANDREYEVICH KRASILNIKOV

vs.

COMMISSIONER OF REVENUE.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

This case concerns the Appellate Tax Board's (board)

decision affirming the Commissioner of Revenue's (commissioner)

denial of a request by the appellant, Nikita Andreyevich

Krasilnikov (taxpayer), for an abatement of his 2019 personal

income taxes.

Background. The taxpayer claimed on his 2019 State income

tax return a deduction of $15,515 for alleged theft losses

related to his trade or business. In his testimony before the

board, as it was described in the opinion of the board, and in a

written statement he submitted to the commissioner, the taxpayer

alleged that the motor vehicle from which he conducts his mobile

sauna business was given to a mechanic for repair of a transmission in 2019. He alleged that the mechanic refused to

return the vehicle, and he brought a criminal complaint against

the mechanic, which the record shows was issued and then

ultimately dismissed. At the end of the 2019 tax year, the

taxpayer had not recovered the vehicle.

Although the record does not explain how, the taxpayer did

recover the vehicle in January 2020. He discovered that the

transmission was not repaired, and that the mechanic had done

some further damage to the vehicle. Although they were not in

the record before the board, we note, as does the commissioner,

that an invoice and letter the taxpayer included in the record

appendix from a different mechanic concluded that "whoever

worked on the Vehicle prior to me did a great disservice to its

Owner. In fact, very little work was done, some parts were

missing, and this caused me to have to do additional work."

According to the taxpayer, the amount paid to the

unsatisfactory mechanic was $5,000, and the cost of the repairs

by a different mechanic was $9,515. Adding $1,000 for what is

described by the parties as an insurance deductible for a repair

on a different vehicle, the taxpayer deducted on his 2019 State

income tax return $15,515 from his income for what he

characterized as theft of property related to his trade or

business.

2 On April 8, 2022, the commissioner sent the taxpayer a

Notice of Selection for Audit. It is uncontested that the

taxpayer submitted several Federal tax forms in his response to

the Notice of Selection for Audit. These included his 2019 Form

1040 and Form 4684, on which he listed this same amount as a

deduction related to "[l]osses from casualty or theft."

The notice of audit determination from the Department of

Revenue disallowed the taxpayer's claimed deduction and stated,

"The Schedule Y line 9 deduction will remain disallowed.

Casualty losses are not an allowable deduction for MA purposes."

The taxpayer therefore was assessed an additional $784 of tax

owed, plus penalties and interest. As of the assessment date,

July 18, 2022, the total was $915.31.

On August 16, 2022, the taxpayer filed a memorandum titled

"Requisition to Invalidate Audit Determination." The

commissioner construed the document as a request for abatement

and denied the taxpayer's request on April 28, 2023. The stated

basis for the denial was that "The Taxpayer failed to

substantiate his casualty/theft loss. The Taxpayer has not

demonstrated that the claimed loss deduction was related to his

trade or business." There was no mention of an inadequacy in

his submission to the commissioner with respect to documenting

the costs he incurred.

3 The taxpayer appealed from the denial of his request to the

board on June 27, 2023. Following a hearing where the taxpayer

testified on his own behalf, the board concluded that "[t]he

appellant did not submit to the Commissioner or to the Board any

detail or documentation supporting the denied deduction,

including, but not limited to: receipts, itemized bills, credit

card statements, and insurance documentation. The Board ruled

that the appellant's resuscitation of his interpretation of the

facts did not constitute substantiation. Therefore, the Board

ruled that the appellant failed to substantiate his claim to

business deduction for the tax year at issue, as was his

burden."

Discussion. 1. Supporting documentation. The original

reason provided in the commissioner's Notice of Audit

Determination appears, as the taxpayer argues, to be in error.

The notice concluded that "Casualty losses are not an allowable

deduction for MA purposes." In his brief before us, the

commissioner states, "[S]tate law permits a deduction for theft

losses parallel to the [F]ederal deduction. G. L. c. 62,

§ 2 (d) (1)." The abatement was denied by the commissioner on a

different ground, that "The Taxpayer failed to substantiate his

casualty/theft loss. The Taxpayer has not demonstrated that the

claimed loss deduction was related to his trade or business."

And the board said the taxpayer did not submit to the

4 commissioner or the board, "any detail or documentation

supporting the denied deduction, including, but not limited to:

receipts, itemized bills, credit card statements, and insurance

documentation." The board has articulated an adequate basis for

denial of the deduction.

Before us, though, the taxpayer argues that, as a matter of

fact, he did submit materials, including receipts, to the

commissioner. He has included in his record appendix bills,

checks, and itemized expenses for costs allegedly incurred that

relate to the claimed deduction. In an affidavit attached to a

separate motion by the taxpayer to stay this appeal and remand

to the board or the commissioner for further factual findings,

the taxpayer swears that, "On May 9, 2022, I transmitted to the

Massachusetts DOR, Audit Division, a packet of evidentiary

materials supporting my . . . deduction for the tax year at

issue. Those materials included, among other items, my

[F]ederal income tax return for the relevant year and Form 4684,

valuation notes, receipts, criminal case records, computation

worksheets, and an explanation of the deductions." He attests

that these are the same materials submitted in the record

appendix.

In his brief, the commissioner asserts that the board found

as a fact that the taxpayer had not submitted the necessary

documentary evidence. A motion to stay the appeal and remand

5 for further proceedings filed by the taxpayer may be read to say

that, despite the board saying in its decision that the taxpayer

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