Charles Shaw - Page 20

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          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.                                                              









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