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seeking purpose. See Interstate Drop Forge Co. v. Commissioner,
326 F.2d 743, 747 (7th Cir. 1964), affg. T.C. Memo. 1963-149.
Respondent argues that many of the expenditures deducted by
petitioner are not ordinary and necessary and are instead
personal expenses not related to the Harwichport property. The
taxpayer must prove that he is entitled to any claimed
deductions. Rule 142(a); New Colonial Ice Co. v. Helvering, 292
U.S. 435, 440 (1935); Welch v. Helvering, supra at 115. This
includes proof of the amount and purpose of the item claimed.
Hradesky v. Commissioner, 65 T.C. 87, 90 (1975), affd. per curiam
540 F.2d 821 (5th Cir. 1976); sec. 1.6001-1(a), Income Tax Regs.
A tax return is not proof of entitlement to a credit or deduction
claimed therein; a tax return merely sets forth the taxpayer's
claim. See Roberts v. Commissioner, 62 T.C. 834, 837 (1974);
Seaboard Commercial Corp. v. Commissioner, 28 T.C. 1034, 1051
(1957).
As a general rule, if the record provides sufficient
evidence that the taxpayer has incurred a deductible expense, but
the taxpayer is unable to substantiate adequately the amount, the
Court may estimate the amount of such expense and allow the
deduction to that extent bearing down heavily on the taxpayer
since the problem is of his own making. 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.
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