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travel and hauling ($389).
Petitioner had no records, claiming she lost them in an
accident. Where the Court is satisfied that the taxpayer is
entitled to some deduction, but where the records are inadequate
to establish the amount of the deduction, the Court may make an
approximation of the amount of the deduction. Cohan v.
Commissioner, 39 F.2d 540, 544 (2d Cir. 1930). In such cases we
are cautioned to bear heavily against the taxpayer “whose
inexactitude is of his own making.” Id. Based on petitioner’s
testimony, we shall allow her to deduct $500 for supplies, $400
for mockups and patterns, and $300 for frames and packaging, in
addition to the $3,024 allowed by respondent.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011