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extent of accepting her reasonably based estimated cost of a
speaker system and a receiver. She has claimed no larger costs
than we have found, and, in any event, the record does not
support our allowing her more. Although we suspect that the
actual cost of goods sold was higher, we cannot make that
estimate absent a demonstration “that at least the amount allowed
in the estimate was in fact spent or incurred for the stated
purpose. Until the trier [of fact] has that assurance from the
record, relief to the taxpayer would be unguided largesse.”
Williams v. United States, 245 F.2d 559, 560 (5th Cir. 1957); see
Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930).
Based on the foregoing, we hold that petitioner had
unreported sales income from Brian and Ted P. and Howard S. in
1989 of $12,929 (i.e., $18,300 gross receipts less $5,371 in
costs of goods sold).
Respondent determined that petitioner had unreported income
of $300 in 1989 from the sale of tickets and tapes to an
individual named David M. In August of 1989, David M. wrote a
check to petitioner individually for $300 for the purchase of
tickets to the Broadway show “Phantom of the Opera”. Petitioner,
however, has provided a receipt showing that she paid $300 for
those tickets. She accordingly has no unreported income from the
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