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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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