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amounts claimed as deductions, credits, etc., by maintaining the
records needed to establish such entitlement. Sec. 6001; sec.
1.6001-1(a), Income Tax Regs.
Petitioner has failed to meet his burden of proof. Rule
142(a). His testimony in response to the question of how he
calculated the deductions claimed on his return was vague and
incoherent. He stated at one point that he relied upon "a lot of
credit card statements" in preparing his return. However, since
hurricane Andrew hit Florida in August 1992, the records that he
purportedly relied upon could not have been destroyed by the
hurricane because his return was not prepared until March 1993.
Nonetheless, such records were not presented at trial. Moreover,
even if we were to accept petitioner's representation that he
maintained records that were destroyed by hurricane Andrew, he
has failed to cooperate with respondent or obtain any copies of
receipts, checks, or credit card statements to substantiate his
claimed itemized deductions, despite the Court's order to do so
at the time we granted the continuance of his case on October 8,
1996.
In the event that a taxpayer establishes that he 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
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