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consider his other arguments. We therefore need not expatiate on
petitioner’s substantive failure to persuade us of the business
necessity for maintaining the apartment or otherwise to supply
sufficient evidence that would have enabled us to apply the Cohan
rule in his favor.
Issue 3. Supplies Expense in Connection With Retreat Activity
Petitioner promoted the ranch as a retreat center called
East/West Retreat, to be used for field trips, classes, getaway
weekends, philosophy seminars, astronomy groups, weddings, and
meditation for personal renewal.
Petitioner estimated that the ranch was used for retreats
approximately 20 times during 1993. Petitioner charged retreat
guests $10 to $25 for 1 day at the ranch and $120 for a full week
at the ranch.
Petitioner deducted $4,369 for supplies for his retreat
activities. Petitioner provided receipts to respondent, which,
however, were not introduced into evidence, for groceries, office
supplies, party favors, and wine. Respondent allowed $666 as a
reasonable estimate of expenses for retreat supplies.2
In the absence of petitioner’s showing at trial that the
claimed expenditures were in fact incurred and were ordinary and
necessary to his activities as a retreat host, respondent’s
determination on this issue is sustained.
2 See supra note 1.
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