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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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