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When a taxpayer establishes that he has incurred a
deductible expense but is unable to substantiate the exact
amount, we are, in some circumstances, permitted to estimate the
deductible amount. See Cohan v. Commissioner, 39 F.2d 540, 543-
544 (2d Cir. 1930). We can estimate the amount of the deductible
expense only when the taxpayer provides evidence sufficient to
establish a rational basis upon which the estimate can be made.
See Vanicek v. Commissioner, 85 T.C. 731, 743 (1985).
Petitioner did not keep books and records for his tutoring
activity. Other than receipts for the repairs and maintenance of
the apartment, the only documentary evidence produced by
petitioner were his and his parents’ Federal income tax returns
for 1995 and 1996. Mr. Antonious testified that we should rely
on the unsigned returns of petitioner’s parents as credible
evidence of payment. We are not required to rely on petitioner’s
and Mr. Antonious’ self-serving testimony and documents. See
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). A taxpayer’s
income tax return is a self-serving declaration that may not be
accepted as proof for the deduction or exclusion claimed by a
taxpayer. See Seaboard Commercial Corp. v. Commissioner, 28 T.C.
1034, 1051 (1957); Halle v. Commissioner, 7 T.C. 245 (1946),
affd. 175 F.2d 500 (2d Cir. 1949). Therefore, petitioner failed
to substantiate the rent, supplies, and legal and secretarial
expenses. Even if petitioner paid his parents, the payments do
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