- 5 - 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 evidencePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011