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income generated by "an activity not engaged in for profit".
Sec. 183(b). An activity not engaged in for profit is one for
which deductions are not allowable under section 162 or section
212(1) or (2). Sec. 183(c).
Generally, when evidence shows that petitioner incurred a
deductible expense, but the exact amount cannot be determined,
the Court may approximate the amount. Cohan v. Commissioner, 39
F.2d 540 (2d Cir. 1930). However, there must be sufficient
evidence from which an estimate may be made. Vanicek v.
Commissioner, 85 T.C. 731, 742-743 (1985). Further, section
274(d) prohibits the estimation of expenses for travel or
deductions with respect to certain property; thus, the Cohan rule
does not apply to these types of expenses. Listed property
includes automobiles. Sec. 280F(d)(4).
Petitioner offered no records to substantiate his travel or
automobile expense aside from the expense log. The expense log
does not meet the substantiation requirements of section 274
because it does not show the date, place, or business purpose of
these expenses or business uses. Sec. 274(d).
Moreover, petitioner has failed to establish that he
incurred any expenses as claimed. Petitioner's testimony was
vague and was not consistent with his expense log. For example,
petitioner testified that his rent expense in 1990 included rent
on his downtown shop of approximately $650 per month. The
expense log shows no such expense. According to petitioner's
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