16 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 inPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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