David M. Priestly, Jr. - Page 12

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          a deduction claimed on the Schedule C included with his spouse’s            
               We reject petitioner’s testimony that he at one time had               
          substantiating documents for the deductions claimed on the                  
          Schedules C included with his 1988 Federal income tax return, but           
          that those documents were seized in the search of his residence.            
          Petitioner has otherwise failed to produce in this proceeding               
          sufficient substantiation for any of the deductions claimed on              
          the Schedules C, and he has not given us a basis upon which we              
          can reasonably estimate the amount of the expenses to which the             
          deductions relate.  See Norgaard v. Commissioner, 939 F.2d 874,             
          877 (9th Cir. 1991); Williams v. United States, 245 F.2d 559, 560           
          (5th Cir. 1957); Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d            
          Cir. 1930); Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985).           
               Petitioner has failed to establish that respondent’s                   
          determination of a deficiency in his 1988 Federal income tax was            
          in any way erroneous.  Respondent’s Appeals officer has verified            
          that the assessments made as a result of that determination are             
          otherwise valid.  Respondent’s determination to proceed with                
          collection is therefore sustained.                                          
               To reflect the foregoing,                                              
                                                  Decision will be                    
                                             entered for respondent.                  

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