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Forestville Oakland
Property Property
Claimed Allowed Claimed Allowed
Cleaning and maintenance $4,073 $405 $2,186 $186
Repairs 4,153 55
Supplies 1,741 1,488
Petitioner also claimed miscellaneous itemized deductions for
travel and transportation expenses of $6,373. Respondent
determined that petitioner was entitled to deductions of only
$4,946.2
A taxpayer generally must keep records sufficient to
establish the amounts of the items reported on her Federal income
tax return. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.
However, in the event that a taxpayer establishes that a
deductible expense has been paid but that she is unable to
substantiate the precise amount, we generally may estimate the
amount of the deductible expense bearing heavily against the
taxpayer whose inexactitude in substantiating the amount of the
expense is of her own making. Cohan v. Commissioner, 39 F.2d
540, 543-544 (2d Cir. 1930). We cannot estimate a deductible
expense, however, unless the taxpayer presents evidence
1(...continued)
Forestville property.
2Respondent’s adjustment to the miscellaneous itemized
deductions pursuant to the sec. 67(a) limitation is computational
and will be resolved by the Court’s holding on the issue in this
case.
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Last modified: May 25, 2011