Helen Sophie Schroeder - Page 16

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          claimed.  New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440                     
          (1934).  Section 6001 requires taxpayers to maintain adequate                      
          records from which their tax liability may be determined.                          
          Petzoldt v. Commissioner, 92 T.C. 661, 686 (1989).                                 
                Respondent conceded that petitioner paid $378 to the State                   
          Bank of Standish in 1992 on an installment loan.  Petitioner's                     
          testimony established that the interest was an ordinary and                        
          necessary expense of carrying on her trade or business.                            
          Consequently, the $378 is deductible.  Sec. 162.  Petitioner has                   
          failed to establish that she is entitled to the remaining portion                  
          of the claimed interest deduction.  Although we believe that                       
          petitioner borrowed money from the Michigan Federal Credit Union                   
          for use in her trade or business, she has not proven the amount.                   
          We cannot use the rule of Cohan v. Commissioner, 39 F.2d 540, 544                  
          (2d Cir. 1930), to estimate the interest deduction because we                      
          must have some basis in fact 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.5                           
          Williams v. United States, 245 F.2d 559, 560 (5th Cir. 1957).                      
          Petitioner's Costs of Goods Sold                                                   

                5  Respondent argues on brief that petitioner has not                        
          substantiated other deductions on her tax returns for 1992 and                     
          1993.  The propriety of these deductions is not at issue as                        
          respondent failed to raise these issues in her notice of                           
          deficiency or in her pleadings.  Generally, we will not consider                   
          issues that are raised for the first time at trial or on brief.                    
          Foil v. Commissioner, 92 T.C. 376, 418 (1989), affd. 920 F.2d                      
          1196 (5th Cir. 1990).                                                              




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