Larry D. & Marie A. Land - Page 9




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          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.                          





















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