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specific statutory requirements entitling them to the claimed
deductions. New Colonial Ice Co. v. Helvering, 292 U.S. 435
(1934); Davis v. Commissioner, 81 T.C. 806, 815 (1983), affd.
without published opinion 767 F.2d 931 (9th Cir. 1985). While
the Court may estimate the amount of allowable deductions where a
taxpayer establishes his entitlement to, but not the amount of,
the deductions, Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d
Cir. 1930), any such estimate must have a reasonable evidentiary
basis, Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985).
Without a reasonable evidentiary basis, the Court’s allowance of
deductions would amount to unguided largesse. Williams v. United
States, 245 F.2d 559, 560 (5th Cir. 1957).
Respondent disallowed amounts claimed on petitioner’s
returns for cost of goods sold, car and truck expenses,
commissions, and “other property lease”. In his posttrial brief,
petitioner claimed $315,000 in alleged payments made to “Alpine
Industries” as cost of goods sold and claimed deductions for
$7,899 in “fiduciary fees”, for $7,436 in car and truck expenses
for travel between petitioner’s Fresno and Merced offices, and
for $11,500 in rent paid for petitioner’s Burbank office. On
brief, petitioner did not cite any evidence in the record to
substantiate these deductions.
The alleged “fiduciary fees” were not claimed on any return
and were not listed by petitioner as a disputed item in the
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