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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 a
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