Roger L. and Geraldine Williams - Page 18

                                        -18-                                          
               Moreover, the checks that petitioners introduced at trial              
          were dated in February and March, well before the Port lease was            
          executed.  We are not convinced that petitioners would have                 
          incurred expenses of $2,285 before entering into the Port lease.            
               In addition, the record demonstrates that petitioners wrote            
          checks for business expenses unrelated to the deduction for                 
          "Repairs and Maintenance", particularly when they wanted to have            
          a record of what they had paid.  That being the case, petitioners           
          did not adequately explain why they dealt exclusively in cash               
          regarding the deduction in issue, especially in view of its                 
          magnitude.                                                                  
               Finally, the Port lease is silent regarding the aesthetic              
          "requirements" for a shoeshine stand or the Port's "right" to               
          impose its aesthetic sensibilities on petitioners.  In any event,           
          petitioners failed to call any representative of the Port to                
          testify regarding the need for the construction of a new                    
          shoeshine stand or the repair of any existing stand.                        
               In view of the foregoing, we hold that petitioners failed to           
          carry their burden of proof.  While under other circumstances we            
          might be inclined to estimate a reasonable allowance, see Cohan             
          v. Commissioner, 39 F.2d 540 (2d Cir. 1930), here, however, there           
          is no basis upon which an estimate may be made, see Vanicek v.              
          Commissioner, 85 T.C. 731, 743 (1985), any allowance would amount           
          to unguided largess, see Williams v. United States, 245 F.2d 559,           






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