The Influencer Who Tried to Deduct the Grammys, the Emmys, and a Dropped Pass From Tom Brady

Suleiman Sami paid $10,000 for two tickets to the Grammys, $8,912 to meet Benedict Cumberbatch, $4,151 to meet Matt Damon — and he dropped a pass from Tom Brady, on video. Then he tried to deduct the experiences, first as charitable contributions and later as marketing for his social-media influencer business. The IRS determined $130,550 in deficiencies, plus penalties. In Sami v. Commissioner, the Tax Court got its first chance to apply the deduction rules to influencer expenses — and the ending was a split decision, with a door deliberately left open.

Who is Suleiman Sami?

By the opinion’s description, Sami is a New York resident with a bachelor’s and a master’s degree in accounting from St. John’s University, who once worked at PricewaterhouseCoopers in risk assurance. During the years at issue — 2019, 2020, and 2021 — he was also a full-time IT employee at JetBlue in Queens.

His side business, S Sami Services LLC, had three parts, all reported on one Schedule C: (1) transportation — driving people he personally knew, in a Mercedes-Benz S550 and a Chevrolet Traverse (later a Lincoln Aviator), without a New York City Taxi and Limousine Commission license; (2) event-ticket sales, a “concierge” service built on hard-to-get tickets; and (3) social media influencing. The combined business reported gross receipts of $169,532 in 2019, $93,229 in 2020, and $133,252 in 2021. One fact would matter enormously later: under the opinion, most if not all of those receipts came from transportation, a small fraction may have come from ticket sales — and none came from social media influencing in those years.

What did he pay to meet?

The opinion lists the experiences one by one. He did not pay the celebrities directly — he paid charities to which the celebrities were donating their time:

• $10,000 for two tickets to the Grammys; $2,700 for two tickets to the Emmys
• $8,912 to meet Benedict Cumberbatch; $4,151 to meet Matt Damon; $2,600 to meet Mark Ruffalo
• $2,025 for a personalized video message from Chris Evans
• $6,500 to attend Tiger Jam 2019, a charity event hosted by Tiger Woods
• $831 to catch a pass from Drew Brees — which he caught; an unspecified amount to catch a pass from Tom Brady — which hit him in the chest and was dropped, even though Sami, a Jets supporter, is not a Brady fan
• $779 to return a serve from John McEnroe, who, by Sami’s own telling, “basically destroyed me on the tennis field”
• $425 for a one-hour training session and lunch with mixed martial artist Chuck “The Iceman” Liddell; at least $50 for a lottery chance to walk a red carpet with Tom Holland; and $6,317 for signed Kobe Bryant game-issue shoes from Bryant’s final season

He posted photos and videos from these encounters. Some posts drew real attention — after a photo with Tom Holland, people messaged him asking how they could meet Holland or Zendaya. By October 23, 2025, the opinion notes, he had around 520,000 TikTok followers, 140,000 Instagram followers, and 4,200 followers on X, and was earning about $25,000 a year in shared advertising revenue. But that revenue came later. In 2019–2021, the influencing itself earned nothing.

Charity first, marketing second — what did the IRS say?

On his original returns, Sami deducted these payments on Schedule A as cash charitable contributions: $61,973 for 2019, $18,875 for 2020, and $40,609 for 2021. In Tax Court, with counsel, he abandoned that framing and argued the payments were Schedule C marketing expenses instead — $42,762, $38,806, and $15,937 for “marketing events and marketing charity” across the three years.

The IRS disallowed these and numerous other deductions. Its notices of deficiency, dated March 15, 2023 (for 2019 and 2020) and August 9, 2023 (for 2021), determined:

• 2019: $63,219 deficiency, plus a $12,644 accuracy-related penalty
• 2020: $27,421 deficiency, plus a $5,484 penalty
• 2021: $39,910 deficiency, plus a $7,982 penalty

Sami was representing himself until the day of trial in New York City; from trial onward he was represented by counsel, including Frank Agostino. The two dockets were consolidated, and Judge Copeland’s opinion — Sami v. Commissioner, T.C. Memo. 2026-69 — was filed on August 18, 2026. Final amounts are being recomputed under the court’s Rule 155 procedure, so treat the figures above as the amounts the IRS determined, not a final bill.

So who won?

Both sides won pieces. The headline items went to the IRS:

• Celebrity experiences: denied. None of the “marketing events and marketing charity” deductions survived, and Sami conceded or abandoned the charitable-contribution argument.
• “General marketing”: denied. The claimed $1,251, $5,215, and $7,832 rested on bank and card lines — PayPal transfers, Ticketmaster and Cameo charges, and charges from services that, for a fee, increase TikTok and Instagram followers. The court was not convinced these were business purchases.
• Television and streaming: denied. DirecTV, Spectrum, Netflix, Hulu, WWE and Apple charges claimed as “market research” ($2,896, $3,211, and $3,766) were held to be personal expenses.
• Also denied: $730 of claimed cost of goods sold for resold tickets, contract-labor payments to his cousins ($600, $600, and $900) with no records of payment, and his cell-phone equipment charges.

But Sami won real money back, too:

• Car and truck: mostly allowed. His vehicles were used directly in transporting people for pay, so the strict substantiation rules for passenger automobiles did not apply. Using his contemporaneous trip vouchers, the court estimated his car expenses and allowed 80% of the amounts tallied on brief: $29,015, $9,464, and $17,414 — plus 80% of his toll and parking estimates ($11,101, $5,042, and $35).
• Credit-card processing fees: allowed in full — $10,904, $6,749, and $9,186.
• Cell-phone service: 25% allowed. He carried four phones on three carriers; the court allowed one phone’s worth of the service charges.
• QBI: his side won the principle. The court held his Schedule C income from transportation and ticket sales is qualified business income from a qualified trade or business under §199A.
• Penalties: sustained. The 20% accuracy-related penalties under §6662(a) were sustained. That part is covered below.

Why did the celebrity deductions fail?

Three reasons, in the court’s order of importance.

First, primary purpose. A business expense under §162 must be primarily undertaken for business, not personal, reasons — and personal expenses are not deductible under §262. The court found Sami’s motives were primarily personal: the experiences were desirable, they brought personal status and stories, he derived considerable enjoyment from them, and he had not initially claimed or viewed them as marketing at all. That the posts later helped his following was not enough. As the court put it, if benefit alone were the test, it “would be met by countless clearly personal expenses, such as a comedian getting good material for her standup act while on a European vacation.”

Second, the business was not yet earning. He had no gross receipts from influencing in the years at issue, the experiences did not materially benefit the driving business, and he showed no written evidence they increased ticket sales. At most, the court suggested, these were early costs of a revenue-sharing line of business that had not yet begun — which would make them startup expenditures to be capitalized under §195, not current deductions under §162.

Third, substantiation. For most items, the evidence was a card or bank line and general testimony. One 2021 charge — “TM *TICKETMASTER LOS ANGELES CA $1,661.57” — had no receipt, no description of what it bought, and no evidence of any post based on it. Other lines said only “PayPal” plus a username and a transaction number. The court also noted Sami kept no books and records for the business, used no accounting software, retained no accountant or tax adviser, and prepared his own returns.

Did the court say influencers can never deduct a fun experience?

No — and that is the part of this case creators should actually read. The court said it “has not had the opportunity to apply these general principles in the context of expenses incurred by social media influencers,” and that such an enterprise “would be no different from other for-profit enterprises, and the same general rules would apply.” An expense does not lose just because it looks like fun. It loses when the taxpayer cannot show it was primarily for business, tied to an existing business, and documented. Sami lost on his facts — the rule itself leaves room for a creator whose facts, and records, are different.

What happened to the penalties?

They were sustained. The court held the §6662(a) penalties were properly approved — the manager’s signature on the 30-day letter sent before the notice of deficiency satisfied the §6751(b) written-approval requirement, even though the date line on a separate approval form was left blank — and that Sami had no reasonable-cause defense. The reason cuts both ways: “Despite having two accounting degrees, Mr. Sami kept no books, and his records were inadequate.” With his background, the court found, he would have been aware he could deduct only purchases with true business purposes, and that he had to document them.

Creating content for a business? The checklist this case hands you

• Write down the business purpose before you spend, not after you are audited. Contemporaneous notes tying the expense to a business goal are evidence; a new theory in Tax Court is not.
• Keep the receipt, not just the card line. A statement showing you paid someone, for something, does not prove what you bought or why.
• Pick one theory and stay with it. The same payments were charitable contributions on the return and marketing expenses in court. The switch itself hurt credibility.
• Separate the money. Sami used his business account and a personal Amex card for both business and personal items — including paying his mother’s credit-card bill — and the commingling undermined item after item.
• Know which business the expense serves. An expense for a line of business that has not started earning may be a startup cost, not a current deduction — different timing, different treatment.
• Posting is content, not proof. Views and followers can show an effect. The court asks about purpose at the time of the spend, plus records.

Alex Volkov, CPA is a New York-licensed CPA with over two decades in accounting, focused on resolving IRS tax problems — back taxes, liens, levies, garnishments, and audits — for individuals and businesses in all 50 states and around the world.