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failed to submit adequate evidence that the postage expenses were
incurred for business purposes, we are persuaded that some
portion of the $421 incurred for postage was related to
petitioner’s business and is therefore deductible. Where the
taxpayer establishes that a deductible expense has been incurred,
but is unable to substantiate the exact amount, the Court may
estimate the amount, bearing heavily if it chooses against the
taxpayer, whose inexactitude is of his own making. See Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). Taking into
consideration the magnitude of petitioner’s business, we find $75
of the postage costs to be deductible by petitioner as a business
expense.
With respect to the remainder of the documented expenses,
petitioner failed to provide us with any credible evidence that
would allow us to conclude that the items were purchased for
business rather than personal use, or otherwise that they were
ordinary and necessary for petitioner’s business. Accordingly,
we hold that petitioner is not entitled to these deductions.
2. Business Meetings
Petitioner claims deductions for $752 in expenses she
asserts she incurred during business meetings in 1999.
Most of the evidence petitioner produced to verify the
expenses comprises handwritten receipts, some of them completed
by petitioner herself, which contain notations of the purpose for
4(...continued)
pads, a stapler, and a planner pad.
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