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reason to be skeptical about the accuracy of the claimed
deductions. For example, in 1991, the largest item deducted was
a round figure of $10,000 as “other expenses” for “Telephone,
Litigation-Reputation, Professional Dues, Library-Law
Publications”. For 1992, petitioner claimed, as “other
expenses”, $15,000 for “Telephone, Litigation Reputation,
Professional Dues, Law Library, Software--Computer Publications”.
The size of these amounts when compared to the purposes for which
they were allegedly spent causes us to doubt their accuracy.
Having reviewed petitioner’s pleadings in this and other cases,
we cannot accept the assertion that he expended these amounts of
money for the purposes set forth.
In any event, it was his obligation to demonstrate the facts
establishing the amount and nature of deductible expenses, and he
has failed to do so. While it is within the purview of this
Court to estimate the amount of allowable deductions where there
is evidence that deductible expenses were incurred, see Cohan v.
Commissioner, 39 F.2d 540 (2d Cir. 1930), we must have some basis
on which an estimate may be made, see Williams v. United States,
245 F.2d 559, 560 (5th Cir. 1957). Because the record contains
no evidence upon which we might base such an estimate, we find
that petitioner has failed to prove that he is entitled to claim
any deductions under section 162(a). See Vanicek v.
Commissioner, 85 T.C. 731, 743 (1985).
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