- 20 - showing how much he spent to travel to the festivals. Thus, petitioner may not deduct more than $4,188 for travel expenses in 1994 and $0 for 1993 and 1995. d. Other Expenses Respondent determined that petitioner did not substantiate, and therefore may not deduct, expenses for electricity, telephone, sewage, water, labor, and transportation used in his business. Petitioner asks us to estimate the amount of these expenses under Cohan v. Commissioner, 39 F.2d 540, 544 (2d Cir. 1930); see also Bayou Verret Land Co. v. Commissioner, 450 F.2d 850, 858 (5th Cir. 1971), affg. 52 T.C. 971 (1969). The taxpayer must present credible evidence that provides a rational basis for our estimate. Vanicek v. Commissioner, 85 T.C. 731, 743 (1985). Petitioner offers only the vaguest estimates of his costs. It is not appropriate under Cohan for us to guess the amounts of his expenses. Thus, petitioner may not deduct any amounts for miscellaneous business expenses. 4. Conclusion as to Unreported Income Petitioner has not shown that he had unreported income less than $139,425 in 1993, $239,655 in 1994, and $375,637 in 1995, as determined by respondent. Thus we sustain respondent’s determination.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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