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furnish all necessary materials to maintain all improvements on
the property, and the Weeldreyers agreed to supply all necessary
labor.
Petitioners have offered no evidence to show that the
expenditures for maintenance and repair, the landscaping, or the
remodeling were costs for materials (Dreyer Farms’ obligation),
as opposed to costs for labor (the Weeldreyers’ obligation).
Although that portion of these expenditures allocable to
materials would be the corporation’s obligation (and would be
deductible by it under section 162(a)), from the record before us
we are unable to reasonably apportion the expenditures between
the costs of labor and materials. While it is within the purview
of this Court to estimate the amount of allowable deductions
where there is evidence that deductible expenses were incurred,
Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930), we must have
some basis upon which to make the estimate, Williams v. United
States, 245 F.2d 559 (5th Cir. 1957). Because we have no such
evidence, we hold that the deductions taken for repair and
maintenance, remodeling, and landscaping are not allowable.
b. Property Insurance
Dreyer Farms deducted $540 in 1995, $1,042 in 1996, and
$1,289 in 1997 for property insurance. “Certain business-related
insurance expenses unquestionably are deductible under section
162(a).” Metrocorp, Inc. v. Commissioner, 116 T.C. 211, 245
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