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expense, but the taxpayer has failed to substantiate the precise
amount, in some situations the Court may estimate the amount of
the expense. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d
Cir. 1930). In so doing, our estimate may be weighted against
petitioner whose inexactitude is of his own making. Cohan v.
Commissioner, supra at 544. For ease of discussion, we have
combined our findings of fact and opinion with respect to each
issue.
Employee Business Expenses
For the past 20 years petitioner has been involved in real
estate and recreation businesses in Charlotte, North Carolina.
Petitioner owns between 25 and 50 percent of several businesses
(the corporations), organized primarily as S corporations, that
own and lease commercial real estate. The corporations' tenants
included three businesses that operate roller skating rinks, a
Family Dollar store, a Circle K gas station and convenience
store, and a BoJangles restaurant. Petitioner served as an
officer, typically secretary, in each of the corporations during
1990 and 1991. Petitioner received no compensation from the
corporations during 1990 or 1991 for his services as an officer
and employee. Petitioner also served as president of Skate
Palace, Inc. (Skate Palace), an entity that operates a roller
skating rink. Skate Palace leases the rink from Rex Annex
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