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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 estimate the amount
of such expense and allow the deduction to that extent. Cohan v.
Commissioner, supra. In order for us to estimate the amount of
an expense, however, we must have some basis upon which an
estimate may be made. Vanicek v. Commissioner, 85 T.C. 731, 743
(1985). Without such basis, any allowance would amount to
unguided largesse. Williams v. United States, 245 F.2d 559, 560
(5th Cir. 1957).
Due to the total absence of documentation and inconsistent
testimony, we are without a reasonable basis to estimate the
amount of compensation payments petitioners made to their sons.
Thus, we decline to apply the Cohan rule. Consequently,
petitioners have failed to satisfy their burden of establishing
their right to this deduction. Accordingly, respondent's
determination regarding this issue is sustained.
Issue 2. Schedule C Equipment Rental Expense Deduction
Petitioners contend that, pursuant to section 162(a)(3),
they are entitled to deduct $7,200 as a business expense on their
income tax return for taxable year 1988. Petitioners attribute
this expense to lease payments paid for the use of six sewing
machines, all of which were used in the ordinary course of their
sewing business. Respondent argues that petitioners' inability
to substantiate the rental expense precludes allowance of the
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