Charles Vernon Roberts - Page 19

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          U.S. 435, 440 (1934).  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).                              
               Section 6001 and the regulations promulgated thereunder                
          require taxpayers to maintain records sufficient to permit                  
          verification of income and expenses.  As a general rule, if the             
          trial record provides sufficient evidence that the 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 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).                                  
               Petitioner testified that the Federal return mirrored the              
          California return.  In addition, petitioner and Mrs. Roberts                
          testified that the amounts claimed on the California return were            
          correct.  Except as noted below, petitioner introduced no                   
          evidence such as bills, invoices, receipts, canceled checks, or             
          other evidence to substantiate the amounts claimed on the                   







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