- 8 - business expenses. Where the Court is satisfied that the taxpayer is entitled to some deduction but where the records are inadequate to establish the amount of the deduction, the Court may make an approximation of the amount of the deduction. Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930). In such cases we are cautioned to bear heavily against the taxpayer “whose inexactitude is of his own making.” Cohan v. Commissioner, supra at 544. We find that $2,000 of the legal fees are deductible under section 162. To the extent that we have not addressed any of the parties' arguments, we have considered them and conclude they are without merit. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011