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Petitioners claimed Schedule C business expenses of $21,578,
including expenses for advertising, utilities, and insurance
expenses. Section 162 provides for deduction of all ordinary and
necessary expenses paid or incurred during the taxable year in
carrying on a trade or business. Petitioners presented no
evidence, documentary or otherwise, to substantiate these
expenses, and we sustain respondent's determination on this
issue.3
As to self-employment tax, petitioner was a self-employed
real estate broker during 1992, and reported the income and
expenses of his business on Schedule C. Petitioner presented no
evidence on this issue. We hold petitioner's income from self-
employment is subject to self-employment tax, see secs. 1401 and
1402, and we sustain respondent's determination on this issue.
Respondent determined that petitioners are liable for the
addition to tax under section 6651(a)(1). That section reads in
pertinent part:
3While petitioners do not argue application of the rule
articulated in Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930),
affg. in part and revg. in part 11 B.T.A. 743 (1928), we note it
does not apply to this case. In Cohan, the court allowed the
taxpayer to make a reasonable approximation of deductions through
the use of detailed evidence of the amount of his expenditures,
even though the taxpayer could not establish the exact amounts.
See id. at 544. Petitioners presented no testimony to which we
could apply the Cohan rule.
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