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this issue. Respondent, after reviewing the material petitioner
belatedly provided, made substantial concessions. This should
prove to petitioner that a wiser course than the one she followed
in this case would be to provide respondent with information when
it is requested.
The Court has reviewed the evidence and finds some instances
in which we allow petitioner additional deductions under the
Cohan rule, keeping in mind the admonition that we bear heavily
against petitioner whose inexactitude is of her own making and
the concept that we must have some basis upon which an estimate
can be made. The rounded amounts of respondent’s concessions,
the Court’s additional allowances, and the total allowed are set
forth below for MBS:
Deductions Respondent Additional Total
Expenses Claimed Conceded Allowances Allowed
Advertising $852 $607 $607
Bad Debts 2,378 0
Car and Truck 3,345 0
Depreciation 2,896 0
Legal 99 115 115
Office 3,516 $764 764
Business property 8,100 6,700 6,700
Repairs 188 0
Taxes/licenses 1,274 879 879
Travels/meals 310 0
Utilities 1,556 454 454
Wages 11,212 11,212 11,212
Other Expenses 23,597 731 731
$59,323 $21,462
Accordingly, we find that petitioner is entitled to deduct a
total of $21,462 of expenses for MBS.
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Last modified: May 25, 2011