- 27 - 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).Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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