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which to make such estimations. See Vanicek v. Commissioner, 85
T.C. at 742-743. For 1991 and 1992, petitioner provided one
utility bill. For 1993, petitioner provided copies of Wisconsin
Electric, Wisconsin Gas, and Milwaukee Water Works bills for her
personal residence which we hold are nondeductible personal
expenses.
Based on the above, we find that petitioner failed to
establish that utility expense deductions in excess of the
amounts allowed by respondent were ordinary and necessary
business expenses. Respondent is sustained on this issue.
8. Donations
Petitioner deducted donations of $600 and $100 in 1991 and
1992, respectively. Respondent disallowed the deductions in full
for both years.
Petitioner testified that donations included items which she
labeled “gifts/donation” in 1991 and “promos” in 1992.
Petitioner further testified that “promos” or “promotions”
included “perks for employees” and other items as a work
incentive. Petitioner’s receipts under “promos” for 1992
included several items of jewelry, wallpaper, interior paint, an
ironing board, gourmet foods, candy, and perfume totaling
$457.90. Petitioner’s 1991 receipts totaled $104.17, which is
far from the claimed deduction of $600.
Not only has petitioner failed to substantiate specific
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