Shigenori Kudo and Motomi Kudo, et al. - Page 67

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          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,              




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