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evidence of the purchase or of the cost of these items was
received into evidence from which we can estimate an allowable
deduction, cf. Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930);
we must have some basis on which an estimate may be made.
Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985).
Respondent's determination that petitioner is not entitled
to depreciation deductions for medical/dental equipment and a
used neon sign will be sustained.
Pennsylvania Property
Respondent determined that petitioner is not entitled to
deduct any claimed expenses associated with the Pennsylvania
property other than $732 in real estate taxes paid by petitioner.
The parties stipulated that certain amounts claimed as supplies
and advertising expense were paid, but respondent does not agree
that the amounts spent related to rental of the Pennsylvania
property. Respondent contends that the advertisement and the
supplies, along with the claimed repairs and depreciation
expenses, are not deductible because petitioner did not hold the
property in the course of a trade or business or for the
production or collection of income during 1991.
The record is totally lacking in credible evidence of
petitioner's attempting to rent the Pennsylvania property. At
trial, petitioner admitted that, at some point during "the
spring" of 1991, he decided to "unload" the property.
Photographs that were admitted as evidence of the repairs that
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