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records to establish the amount of their deductions. Sec. 6001.
Under certain circumstances, when taxpayers establish that they
incurred a trade or business expense but do not substantiate the
amount of the expense, the Court may estimate the amount of the
deductible expense. Cohan v. Commissioner, 39 F.2d 540, 543-544
(2d Cir. 1930). The estimate must, however, have some reasonable
evidentiary basis. Vanicek v. Commissioner, 85 T.C. 731, 743
(1985). In estimating the amount deductible, the Court considers
that taxpayers' inexactitude is of their own making. Cohan v.
Commissioner, supra at 544.
Initially, we do not accept petitioners's testimony that he
was engaged in any profit-seeking activity concerning the growing
of trees. Secondly, we cannot find that petitioner’s travel was
ordinary or necessary in connection with either his leasing
activity or investment goals. Simply, the travel was for
petitioner’s personal convenience to be with his family.
We have found, however, that petitioners repaired and
maintained the farm property in connection with their leasing
activity and, based on the record, find that they are entitled to
a total deduction of $1,500 in Schedule F expenses for each of
the 3 taxable years.
Petitioner’s testimony regarding the claimed contribution
deductions was generally not credible and was uncorroborated.
However, we find that petitioner Irene E. Ward did regularly make
cash contributions upon her visits to church. Relying on Cohan
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