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Petitioner also testified that he is a member of the State
of Connecticut Bar. He further testified that he attended
Continuing Legal Education seminars, Connecticut Bar Association
seminars, and subscribed to the Connecticut Bar Journal.
However, petitioner failed to submit any corroborative evidence
regarding his dues or the costs of attending those seminars.
Again, petitioner offered no testimony that he even attempted to
reconstruct or obtain any receipts from those organizations.
Petitioner raises Cohan v. Commissioner, 39 F.2d 540 (2d
Cir. 1930). Petitioner argues that he is entitled to his claimed
expenses despite the absence of any certainty as to the exact
amount of those expenses. We conclude that the so-called Cohan
rule has no application where, as here, the record lacks any
basis for estimation. Vanicek v. Commissioner, 85 T.C. 731,
742-743 (1985).
Given the lack of any substantiating evidence, we cannot
sustain any of petitioner's claimed expenses. Accordingly, we
conclude that petitioner has not met his burden of proof for
either year at issue. Respondent, therefore, is sustained. We
need not decide respondent's alternative argument.
We must next decide whether petitioner is entitled to
additional itemized deductions. In the notice of deficiency,
respondent reduced petitioner's income by $8,556 and $8,242 for
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