- 7 - 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 forPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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