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warranted.3
Business related telephone calls were made from petitioner’s
office, her mother’s home (in 1991 and part of 1992), and the
Cass St. address from September 1992 through 1993. Petitioner
did not identify which phone calls were personal or business
related. Petitioner testified that she “just put it in the
computer. I was thinking it was kind of done in the system”.
Petitioner also deducted the electricity at the Cass St. address
for the washer and dryer and charging of equipment. Petitioner
provided copies of her home telephone bills without any
indication of which calls were personal or business related and
copies of her business phone bills with missing monthly
statements.
Petitioner further contends that water, electricity, and gas
expenses were incurred in the ordinary course of business.
Heaters kept equipment and supplies warm, water was used to mix
chemicals, and the washer and dryer were used to launder dirty
towels and clothing.
Although it is within the purview of the Court to estimate
the amount of allowable deductions where there is evidence that
deductible expenses were incurred, Cohan v. Commissioner, 39 F.2d
at 543-544, we cannot do so when there is no reliable evidence on
3 Petitioner attempted to claim the yellow page
advertisements as an additional expense for the years in issue,
in addition to the amounts previously claimed.
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