- 9 - and other documents with a cover sheet stating that these expenses totaled $10,247. Petitioners claimed $7,424 of expenses on their return. The amounts claimed on their return and the amounts petitioners asserted were substantiated at trial are as follow: Claimed Argued on Return at Trial Postage $1,108 $1,104 Copies/faxes 850 655 Training meeting 105 105 Convention fees 210 220 Convention merchandise 464 907 Business reports 90 169 Parking 82 82 Tolls/Food for home meetings 662 736 Bus charter to meeting 240 240 Tapes/Magazines/Books 1,691 2,160 Sales aides 1,042 2,830 Giveaways 880 1,039 7,424 10,247 We may estimate the amount of a deductible expense, but there must be sufficient evidence in the record to permit the Court to conclude that a deductible expense was incurred for the stated purpose and at least in the amount estimated. See Williams v. United States, 245 F.2d 559, 560 (5th Cir. 1957) (citing Cohan v. Commissioner, supra). Many of the expenses in this category appear likely to have been personal in nature, and petitioners were unable to provide details regarding many of them. Thus, petitioners have presented this Court with a number of receipts, but have failed to give the Court any reasonable method to determine which receipts were business, personal, or aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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