Craig V. Adams - Page 9

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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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