Richard William Corduan - Page 6

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          the cost of maintaining the household for the taxable year.  See            
          sec. 2(b)(1); sec. 1.2-2(c), Income Tax Regs.                               
               Nothing in the record shows or even estimates an amount                
          which petitioner provided for his mother's support or to maintain           
          the home.  The Court finds that petitioner did not provide over             
          half his mother's support for 1999.  Therefore, because                     
          petitioner may not claim a dependency exemption deduction for               
          either of his parents, petitioner is not entitled to head of                
          household filing status.  The Court upholds respondent's                    
          determinations with respect to both dependency exemption                    
          deductions and filing status.                                               
          Schedule C Deductions                                                       
               A taxpayer generally must keep records sufficient to                   
          establish the amounts of the items reported on his Federal income           
          tax return.  See sec. 6001; sec. 1.6001-1(a), (e), Income Tax               
          Regs.  However, in the event that a taxpayer establishes that a             
          deductible expense has been paid but is unable to substantiate              
          the precise amount, the Court generally may estimate the amount             
          of the deductible expense, bearing heavily against the taxpayer             
          whose inexactitude in substantiating the amount of the expense is           
          of his own making.  See Cohan v. Commissioner, 39 F.2d 540, 543-            
          544 (2d Cir. 1930).  The Court cannot estimate a deductible                 
          expense, however, unless the taxpayer presents evidence                     








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