- 6 -
115 (1933). Moreover, deductions are a matter of legislative
grace, and the taxpayer bears the burden of proving that he or
she is entitled to any deduction claimed. Rule 142(a); New
Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v.
Helvering, supra. This includes the burden of substantiation.
Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam
540 F.2d 821 (5th Cir. 1976).
If the record provides sufficient evidence that a taxpayer
has incurred a deductible expense, but the taxpayer is unable to
adequately substantiate the amount of the deduction to which he
or she is otherwise entitled, the Court may, under certain
circumstances, estimate the amount of such expense and allow the
deduction to that extent. Cohan v. Commissioner, 39 F.2d 540,
543-544 (2d Cir. 1930). However, in order for the Court to
estimate the amount of an expense, we must have some basis upon
which an estimate may be made. Vanicek v. Commissioner, 85 T.C.
731, 743 (1985). Without such a basis, any allowance would
amount to unguided largesse. Williams v. United States, 245 F.2d
559, 560 (5th Cir. 1957).
Issue 1. Self-Employment Taxes
Section 1401 imposes a tax on an individual's self-
employment income, which is based on the "net earnings from self-
employment" derived by the individual during the taxable year.
Sec. 1402(b). Net earnings from self-employment are the gross
income derived by the individual from any trade or business
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