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trial record provides sufficient evidence' that the taxpayer has
incurred a deductible expense, but the taxpayer is unable to
adequately substantiate the exact 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, 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).
We now address each category of disallowed items
independently.
1. Schedule A Deductions
On Schedule A of their 1990 Federal income tax return,
petitioners claimed, and respondent subsequently allowed, the
following deductions:
Item Claimed Allowed
Real estate taxes $ 2,238 $ 2,238
Personal interest (10 percent) 4,443 46
Charitable contributions 7,383 1,200
Payment worker's comp. fund 10,207 -0
Mortgage interest 12,793 12,375
On Schedule A of their 1991 Federal income tax return,
petitioners claimed, and respondent subsequently allowed, the
following deductions:
Item Claimed Allowed
Real estate taxes $ 3,221 $ 2,463
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