- 6 - We first examine the disallowed Schedule C deductions in issue. On their 1991 return, petitioners claimed Schedule C expenses related to Mr. Brown's tree stumping business in the amount of $194,059. After concessions,3 respondent disallowed $84,021 of those business expenses on the grounds that petitioners failed to substantiate that the amounts were paid and were for business purposes. At trial, petitioners testified that they incurred certain expenses, as discussed infra. We are satisfied by the testimony of petitioners that, in carrying out his tree stumping business, Mr. Brown incurred expenses beyond those allowed by respondent in the notice of deficiency. Because petitioners have not established the precise amount of the deductions, however, we shall make a reasonable approximation of the amounts allowable, "bearing heavily" upon petitioners as permitted by Cohan v. Commissioner, supra at 543. Petitioners claimed interest expenses in the amount of $9,390, which respondent allowed to the extent of $1,392. Accordingly, the amount remaining in issue is $7,998. At trial, petitioners provided neither documentary evidence nor testimony to substantiate the additional $7,998 in interest expenses that they claimed. Moreover, they failed to offer any reconstruction of the amounts through third party records. Consequently, as there is no rational basis to approximate those expenses, we 3 See supra note 1.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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