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Moreover, petitioner’s monthly checking account statements, in
and of themselves, do not constitute adequate substantiation for
purposes of the general recordkeeping requirements of sections
162 and 212. See generally sec. 6001 and sec. 6001-1, Income Tax
Regs., requiring a taxpayer to maintain records sufficient to
enable the Commissioner to determine the taxpayer’s correct tax
liability.
We recognize that under certain circumstances, the Court may
estimate the amount of a deductible expense and allow the
deduction to that extent. See Cohan v. Commissioner, 39 F.2d
540, 543-544 (2d Cir. 1930). However, in order to estimate the
amount of an expense, we must have some basis upon which an
estimate may be made. See Vanicek v. Commissioner, 85 T.C. 731,
743 (1985). Without such a basis, any allowance would amount to
unguided largesse. See Williams v. United States, 245 F.2d 559,
560 (5th Cir. 1957).
In the present case, we need not decide whether it is
appropriate to exercise our discretion under the Cohan rationale
because the maximum deduction to which petitioner might be
entitled under section 183(b) for 1997; i.e., $1,400, would have
no tax effect. This is the case because petitioner’s “health,
wealth and healing ministry” activity was not engaged in for
profit; thus, any section 183(b) deductions would not be
allowable from gross income, but rather it would only be
allowable from adjusted gross income as miscellaneous itemized
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