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operation of such a business he would have incurred expenses for
advertising, telephone, supplies, car and truck, and commissions.
Deductions are strictly a matter of legislative grace. INDOPCO,
Inc. v. Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice
Co. v. Helvering, 292 U.S. 435, 440 (1934). Taxpayers must
substantiate claimed deductions. Hradesky v. Commissioner, 65
T.C. 87, 89 (1975), affd. per curiam 540 F.2d 821 (5th Cir.
1976). Moreover, taxpayers must keep sufficient records to
establish the amounts of the deductions. Meneguzzo v.
Commissioner, 43 T.C. 824, 831 (1965); Sec. 1.6001-1(a), Income
Tax Regs. Generally, except as otherwise provided by section
274(d), when evidence shows that a taxpayer incurred a deductible
expense, but the exact amount cannot be determined, the Court may
approximate the amount, bearing heavily if it chooses against the
taxpayer whose inexactitude is of his own making. Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). The Court,
however, must have some basis upon which an estimate can be made.
Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985).
1. Claimed Expenses for Advertising, Telephone, Supplies, and
Commissions
Petitioner's check register, for the most part, showed his
expenses in a consistent manner. Thus, we are able to estimate
some of the claimed expenses. In addition to the allowance of
the $2,890 for the advertising and telephone expenses agreed to
by the parties, we find that petitioners are entitled to deduct
additional expenses of $1,856 for advertising and telephone. We
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