Sheila Mae Howard - Page 10

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          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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