- 18 - Oxford Dev. Corp. v. Commissioner, T.C. Memo. 1964-182; see also Interstate Transit Lines v. Commissioner, 319 U.S. 590, 593-594 (1943); Deputy v. du Pont, 308 U.S. at 493-494. On the basis of the cost balances of aircraft on hand by Dolphin as compared to the entire controlled group, we find that the following are the percentages of the total cost of aircraft of the entire group held for sale and lease which were owned by Dolphin during the years in issue: FYE 1991 FYE 1992 FYE 1993 41.2% 38.0% 46.6% Because Mr. Ciaravella had interests in entities other than Dolphin that owned aircraft, we are not convinced that the entire amount spent by Dolphin on race car expenditures reasonably compares with the benefit that it, as opposed to other members of the Ciaravella controlled group, could reasonably expect to derive. When Mr. Ciaravella made contacts at the races, he was trying to sell and lease aircraft held by Dolphin, Nomad, and Sarasota, not Dolphin exclusively. Consequently, Dolphin is not entitled to deduct, on the Icarus consolidated return, the entire amount of the race car expenses that it paid. Where a taxpayer establishes his entitlement to a deduction, but does not establish the amount of that deduction, we are permitted to estimate the amount allowable, Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Rolland v. Commissioner, T.C. Memo. 1959-161, affd. 285 F.2d 760 (5th Cir. 1961); Gill v. Commissioner, T.C. Memo. 1994-92; Boomershine v.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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