- 9 - 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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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