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support them. Thus, we cannot infer from the evidence how much
of the funds actually was used to support petitioner's mother and
sister as opposed to Mrs. Olvera and petitioners' daughters.
Furthermore, petitioner testified that his sister, who may
have worked, received money from another source. He also
acknowledged that his nine siblings helped provide support at
times, although he stated that his parents did not receive any
governmental support or insurance. Thus, petitioners have failed
to establish the total amount of support provided for
petitioner's mother and sister from all sources, a prerequisite
to finding that petitioners provided one-half of either
individual's support. See Blanco v. Commissioner, 56 T.C. 512,
514 (1971). Respondent is sustained on this issue.
Schedule C Deductions
Petitioners contend that they are entitled to Schedule C
deductions in the amounts disallowed by respondent. Section 162
allows a deduction for all ordinary and necessary expenses paid
or incurred in carrying on a trade or business. Generally, when
evidence shows that the taxpayers paid a deductible expense but
the exact amount cannot be determined, the Court may approximate
the amount. Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930).
An exception to the Cohan rule is section 274(d), which requires
strict substantiation of certain expenses, including those paid
or incurred with respect to certain listed property. Sec.
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