- 67 - however, lacks specificity as to the amounts Motomi incurred in 1988 and 1989 in performing business-related activities in her home on Toraya's behalf, or even as to how Toraya arrived at the amounts it paid to Motomi in those years. In our view, the amounts claimed appear excessive for the alleged purpose. Accordingly, Toraya has failed to prove that these payments to Motomi were business related and reasonable in amount. Nonetheless, we are persuaded that Motomi performed some business-related activities pertaining to Toraya in her home and incurred some expense for that purpose. Under those circumstances we may make a reasonable estimate, bearing heavily against the taxpayer whose inexactitude is of his or her own making. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). We find that Toraya is entitled to deduct $520 for each of 1988 and 1989 for reimbursement of Motomi's expenses incurred in performing business-related activities in her home on Toraya's behalf. Adjustments to Purchases Expense In the notices of deficiency for 1988, 1989, 1990, and 1991, respondent reduced Toraya's "Purchases Expense" included in cost of goods sold for those years by $57,733, $36,131, $25,230, and $24,000, respectively, on the ground that Toraya had not established that the those amounts were for purchases or were paid during those years. Subsequently, in a stipulation of settled issues, respondent conceded that for 1988, 1989, 1990,Page: Previous 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 Next
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