Carol Anderson - Page 7

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          business expenses on her 1992 return in the total amount of                 
          $6,392.  In the statutory notice of deficiency, respondent                  
          disallowed $6,172 of the claimed expenses.                                  
               Section 162(a) allows a deduction for the ordinary and                 
          necessary expenses paid or incurred during the taxable year in              
          carrying on a trade or business.  In the event that a taxpayer              
          establishes that she has paid a deductible expense, but is unable           
          to substantiate the precise amount of the expense, we may                   
          estimate the amount of the deductible expense.  Cohan v.                    
          Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930).  In order to             
          make such an estimate, the taxpayer must present evidence                   
          sufficient to provide some rational basis upon which an estimate            
          may be made.  Vanicek v. Commissioner, 85 T.C. 731, 743 (1985).             
               Based on the record, we find that petitioner has failed to             
          substantiate the business expense deductions claimed on her 1992            
          return in connection with her promotion activities.  Further, she           
          has not provided the Court with any evidence that would allow us            
          to make an estimate of her deductible business expenses under the           
          Cohan rule.  Therefore, we hold that she is not entitled to                 
          business expense deductions for 1992 in excess of the amount                
          allowed by respondent.                                                      
               The fifth issue for decision is whether petitioner is liable           
          for self-employment tax for 1992.  After accounting for her                 
          allowed deductions, petitioner realized net income in the amount            






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