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a deduction claimed on the Schedule C included with his spouse’s
return.
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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