- 7 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011