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well as security service on the home * * * and the
installation of five new doors for increased security.
* * *
Petitioner's assertion is contrary to well-established law.
Section 262 specifically precludes deductions for personal,
living, or family expenses. Section 1.262-1(b), Income Tax
Regs., lists examples of disallowed expenses, including the types
claimed by petitioner. To the extent that petitioner also claims
that the home is "an alternative office", she has not satisfied
any of the requirements of section 280A(c).
Petitioner's demonstrated penchant for claiming
nondeductible personal expenses as business expenses undermines
the reliability of her assertions with respect to supplies and
other expenses that normally would be deductible. She asks that
the Court estimate such expenses under the doctrine of Cohan v.
Commissioner, 39 F.2d 540 (2d Cir. 1930). That case suggests
that we make an allowance "bearing heavily * * * upon the
taxpayer whose inexactitude is of * * * [her] own making." Id.
at 544. We conclude that petitioner is entitled to deduct $500
on Schedule C for supplies and services relating to her tutoring
and counseling activity. There is no basis for making any
estimate of deductions on Schedule A not allowed by respondent.
Our discussion of the lack of evidence substantiating
petitioner's right to the deductions that she claimed on her
return leads also to the conclusion that petitioner underpaid her
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