- 20 - 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.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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