James H. Shelton, Deceased, and Eve Shelton - Page 7

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          may estimate them when we are convinced from the record that the                   
          taxpayer has incurred such expenses and we have a basis upon                       
          which to make an estimate.  Cohan v. Commissioner, 39 F.2d 540                     
          (2d Cir. 1930); Vanicek v. Commissioner, 85 T.C. 731, 742-743                      
          (1985).  However, the principle established in Cohan v.                            
          Commissioner, supra, does not apply to deductions for travel, as                   
          such deductions are subject to the specific substantiation                         
          requirements imposed by section 274(d).                                            
                Respondent does not dispute that petitioner's "education                     
          business" constituted a trade or business within the meaning of                    
          section 162(a) for 1992, as indicated by the fact that in the                      
          notice of deficiency she has allowed portions of some of the                       
          business expense deductions claimed on the Schedule C.                             
          Furthermore, she now concedes that petitioners are entitled to a                   
          Schedule C rent expense deduction, but only in the amount of                       
          $1,772.35.                                                                         
          I. Cost of Goods Sold                                                              
                Petitioner's 1992 Schedule C reflected gross receipts in the                 
          amount of $7,271 and cost of goods sold in the amount of $7,030.                   
          Petitioner computed cost of goods sold by including expenditures                   
          allegedly incurred in connection with both the book marketing                      
          activity and educational seminars activity.  In the notice of                      
          deficiency, respondent completely disallowed the cost of goods                     
          sold claimed.  According to respondent, petitioner has failed to                   






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