- 9 -
Wilkinson v. Commissioner, supra at 639; Roberts v. Commissioner,
supra at 837; see also Seaboard Commercial Corp. v. Commissioner,
28 T.C. 1034, 1051 (1957) (a taxpayer’s income tax return is a
self-serving declaration that may not be accepted as proof for
the deduction or exclusion claimed by the taxpayer); Halle v.
Commissioner, 7 T.C. 245 (1946) (a taxpayer’s return is not self-
proving as to the truth of its contents), affd. 175 F.2d 500 (2d
Cir. 1949).
At trial, petitioner did not introduce any documentary
evidence to support that she is entitled to deductions with
respect to the Anchor Inn in excess of the amounts allowed by
respondent. Likewise, petitioner did not offer testimony at
trial in support of any of those deductions.
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 the instant case, we have no basis whatsoever
on which to approximate any additional deductible expenses with
respect to petitioner’s operation of the Anchor Inn. See Vanicek
v. Commissioner, 85 T.C. 731, 743 (1985). In view of her failure
to substantiate, we hold that petitioner is not entitled to the
deductions claimed on her Schedules C with respect to the Anchor
Inn in excess of the amounts allowed by respondent in the notice
of deficiency.
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