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alleged import/export business. Moreover, petitioner has failed
to present convincing evidence that he reimbursed his brother for
these alleged expenses.
With regard to the other claimed expenses, petitioner has
failed to present any document or testimony to substantiate them.
We have no reasonable evidentiary basis on which to make an
estimate pursuant to Cohan v. Commissioner, 39 F.2d 540 (2d Cir.
1930).
Even if we were to find that petitioners’ claimed deductions
were substantiated, petitioner has failed to establish that his
alleged import/export activity went beyond the preopening stage
during 1992 and 1993. Petitioner argues that he reported income
for the activity in prior years, and therefore the activity had
progressed beyond the preopening stage during the years in issue.
On a Schedule C attached to his 1990 Federal income tax return,
petitioner reported gross income from the import/export activity
of $5,000 and deductions of $28,004, resulting in a net loss of
$23,004. On a Schedule C attached to his 1991 Federal income tax
return, petitioner reported gross income from the import/export
activity of $7,170 and deductions of $23,510, resulting in a net
loss of $16,340. Petitioner’s 1991 Schedule C indicates that
$5,500 of the $7,100 of income reported was received for “setting
up” a medical practice. Moreover, on the Schedules C attached to
his 1990 and 1991 Federal income tax returns petitioner reported
only minimal amounts of income and claimed larger deductions
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