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to petitioner, was a “a little area * * * [connected to the
living room] that has all the office equipment.” This testimony
is sharply inconsistent with petitioner’s allocation and suggests
that the portion used, if any, as a home office by petitioner was
substantially less than the 50 percent she claims. While Cohan
allows us to estimate the amount of expense that we find to be
deductible when the exact amount cannot be ascertained, in order
for us to do so, petitioner must have supplied us with some basis
upon which an estimate can be made. See Vanicek v. Commissioner,
85 T.C. 731, 742,743 (1985). Petitioner, however, has failed to
provide the Court with any measurements, pictures, floor plans,
or any other evidence that would enable us to estimate the
portion allocable to the home office.
Accordingly, having failed to substantiate that a portion of
her home was used exclusively for business purposes, petitioner
is not entitled to a deduction for these expenses.
B. Head-of-Household Filing Status and Dependency Exemption
Petitioner filed her Federal income tax return for 2000 as a
head of household and claimed the dependency exemption deduction
for her brother.
In order to qualify for head-of-household filing status, a
taxpayer must satisfy the requirements of section 2(b). Pursuant
to this section, an individual qualifies as a head of household
if she (1) is not married at the close of the taxable year, and
(2) maintains as her home a household that constitutes for more
than one-half of the taxable year the principal place of abode,
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