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While it is within the purview of this Court to
estimate the amount of allowable deductions where there
is evidence that deductible expenses were incurred
(Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930)), we
must have some basis on which an estimate may be made.
Williams v. United States, 245 F.2d 559 (5th Cir.
1957). * * *
Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). Since the
record contains no evidence from which the Court could make such
an estimate, we must find that petitioner failed to substantiate
the cost basis of the J car.11
Accordingly, we conclude that petitioner's deductions for
depreciation related to the J car must be disallowed.
To reflect the concessions and above holdings,
Decision will be entered
under Rule 155.
11 Thus, we need not address respondent's argument that it
is not possible to attribute a 3-year or other specific period of
useful life to the car.
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