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status for the 1990 taxable year. Respondent is sustained on
this issue.
2. Whether Petitioner Is Entitled to Deductions for Expenses
Incurred While Working as a Dockhand on a Commercial Fishing Boat
Pursuant to Cohan v. Commissioner, 39 F.2d 540 (2d Cir.
1930), we are permitted to estimate expenses when we are
convinced from the record that the taxpayer has incurred such
expenses. In Hadsell I, we found that petitioner was entitled to
deduct $750 as business expenses attributable to his fishing
activity for each year of the years at issue.
At trial on January 30, 1998, petitioner failed to adduce
any additional evidence substantiating his claimed expenses.
Therefore, we do not change our previous finding that petitioner
is entitled to deduct $750 as business expenses attributable to
his fishing activity for each year of the years at issue.
3. Deductions Related to Rental Property
Petitioner contends that he is entitled to deduct expenses
with respect to rental real property he purchased in 1989 and
also claim a casualty loss for items he had stored on the rental
property which were sold by the tenants.
In Hadsell I, we found that petitioner’s testimony
concerning his claimed expenses and casualty losses was vague and
unsupported and that we had no basis to allow petitioner to claim
either a rental property expense or casualty loss for the years
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