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those allowed by respondent. Accordingly, we sustain
respondent’s determination on this issue.
Travel, Meal, and Entertainment Expense Deductions
Petitioner claimed deductions on his Schedules C for the
years in issue for travel, meal, and entertainment expenses. To
the extent substantiated, respondent allowed deductions for a
portion of the travel and meal expenses on the Schedules C and a
portion of those expenses on petitioners’ Schedules A as medical
expenses or investment-related expenses. Respondent did not
allow petitioner to deduct the balance of the claimed travel,
meal, and entertainment expenses because those expenditures were
unsubstantiated or personal.
When a taxpayer establishes that he paid or incurred a
deductible business expense, but does not establish the amount
of the deduction, the Court may estimate the amount allowable in
some circumstances. See Cohan v. Commissioner, 39 F.2d 540, 543-
544 (2d Cir. 1930), affg. 11 B.T.A. 743 (1928). There must be
sufficient evidence in the record, however, to permit the Court
to conclude that a deductible expense was incurred in at least
the amount allowed. See Williams v. United States, 245 F.2d 559,
560 (5th Cir. 1957); Vanicek v. Commissioner, 85 T.C. 731, 743
(1985). In estimating the amount allowable, the Court bears
heavily upon the taxpayer whose inexactitude is of his or her own
making. See Cohan v. Commissioner, supra at 544.
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