- 12 - Subsidiaries v. Commissioner, 699 F.2d 450, 453 (8th Cir. 1983), affg. 78 T.C. 458 (1982). Under certain circumstances, we may estimate costs and allowable deductions. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). The estimates, however, must have a reasonable evidentiary basis. Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). Respondent argues that petitioner has not adequately substantiated any costs and capital improvements to her home in excess of the $221,633 that respondent has agreed to. The claimed costs and improvements still in dispute relate to the years 1971 through 1986, for which petitioner has minimal or no documentation. Respondent argues that petitioner's testimony as to the costs of the claimed improvements is self-serving and uncorroborated. Petitioner claims that the evidence relating to the improvements allegedly made during 1971 through 1986 is adequate for the Court to estimate the costs thereof and that she should be entitled to increase the tax basis in her home by an additional $156,050 beyond those items allowed by respondent, for a total tax basis in the home of $377,683. Credible evidence adequately establishes that, during the years 1971 through 1986, petitioner and her husband made extensive capital improvements to the home. In addition to thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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