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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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