John M. Schaefer - Page 16

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          business.  Sec. 162(a).  We may estimate the amount of the                  
          deductible expense if a taxpayer establishes that he or she paid            
          a deductible expense but cannot substantiate the precise amount.            
          Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930), affg.           
          in part and remanding in part 11 B.T.A. 713 (1928).  The taxpayer           
          must present evidence that provides a rational basis for our                
          estimate.  Vanicek v. Commissioner, 85 T.C. 731, 743 (1985).                
               Petitioner offered but we did not admit copies of records              
          which he said would substantiate his Schedules C and E expenses             
          for 1991 and 1992.  Petitioner argues that his testimony                    
          establishes that he is entitled to deduct the expenses on his               
          1991 and 1992 returns.  He also contends that his deductions were           
          reasonable and that we should not disallow them even though he              
          did not provide documentation.                                              
               Petitioner did not meet his burden of proving the amount of            
          his rental expenses.  There is no evidence of the amount of                 
          interest he paid or of his other expenses for 1991 and 1992.                
          Petitioner's testimony about his expenses was vague and general.            
          He did not provide enough detail in his testimony for us to                 
          estimate the amount of his expenses for 1991 and 1992 under                 
          Cohan.  Although petitioner gave some examples of his expenses in           











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