Danielle L. Clark-Hernandez - Page 21




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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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