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accountants who prepared the income tax returns or the attorney who
represented petitioners until 2 months before trial.
In order for the Court to estimate the amount of a deductible
expense, we must have some basis upon which an estimate may be
made. Vanicek v. Commissioner, 85 T.C. at 743. Here, there is no
such basis, and were we to nonetheless permit any allowance, such
would amount to unguided largess. Williams v. United States, 245
F.2d at 560. Although we are sympathetic with petitioner’s plight,
the fact remains that petitioner failed to present even a modicum
of evidence to substantiate the disallowed deductions.
II. Self-Employment Taxes
Respondent determined that petitioners are liable for self-
employment tax of $10,893 for 1993, $11,753 for 1994, and $27,203
for 1995.
Petitioner was self-employed during each of the years at
issue. He reported the income and expenses of his business on a
Schedule C. Petitioner presented no evidence on this issue. We
thus hold petitioner is liable for the self-employment tax under
section 1401 on his Schedule C earnings for 1993, 1994, and 1995,
as determined in the notice of deficiency. Respondent’s
determination on this issue is sustained.
III. Section 6651(a)(1) Additions to Tax
Respondent determined that petitioners are liable for the
addition to tax under section 6651(a)(1) as a result of
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