Wayne and June Ellen Hairston - Page 6

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          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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