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basis of a horse named Jetta by estimating a fair market value of
$3,600 as of January 1, 1988, while acknowledging that he had
purchased the horse for less than that amount.
Nevertheless, we believe that petitioners likely acquired,
for consideration, some of the assets underlying the disputed
claims for depreciation. Petitioners had bases in these assets
upon which they could claim depreciation. Where a taxpayer
establishes that he or she has incurred a trade or business
expense but cannot substantiate the precise amount of the
expense, we may estimate the amount of the deductible expense,
including expenses attributable to depreciation. Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Bell v
Commissioner, 13 T.C. 344, 347-348 (1949). We cannot, however,
allow a deduction unless the taxpayer presents some rational
basis upon which estimates may be made. Vanicek v. Commissioner,
85 T.C. 731, 743 (1985). In this instance, petitioners' failure
to substantiate the costs of the assets underlying their claims
for depreciation would reduce any attempt on our part to estimate
petitioners' depreciation expenses to little more than guesswork.
We, therefore, sustain respondent's determination.
(d) 1992 Office Expenses
We now address petitioners' claim for a deduction for office
expenses in the amount of $958. Petitioners did not discuss this
issue at trial, and the record contains no evidence to
substantiate the claimed expenses. Petitioners have failed to
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