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2. Automobile Depreciation
Having decided that petitioner failed to substantiate his
mileage, we are compelled to disallow petitioner’s claimed
depreciation deduction as well--to claim any deduction related to
use of his personal automobile, petitioner must meet the enhanced
substantiation requirements. Whalley v. Commissioner, T.C. Memo.
1996-533.
3. Interest
Petitioner claimed $7,392 in interest expenses. To the
extent that this amount reflects otherwise deductible mortgage
interest, respondent allowed its deduction in the notice of
deficiency, and we sustain that allowance.
Petitioner also submitted documentation of $4,880 in
interest expenses from his various credit cards. In Exhibit 17-
P, petitioner showed that the proper percentage of credit card
interest allocable to his Schedule C expenses is 78 percent. We
believe this amount is overly generous to petitioner, especially
in light of the excess claims we find he made in the supply
category. See infra. Still, petitioner has shown that he paid
substantial interest charges on many consumer credit cards for
expenses properly attributable to his Schedule C activities.
Under the Cohan rule, when presented with some factual basis upon
which to rely, we are allowed to estimate the amount of interest
deductions properly allowable. Schroeder v. Commissioner, T.C.
Memo. 1996-336. We estimate that 65 percent of the claimed
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