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There is no evidence in the record that petitioner complied
with the requirements of section 152, and the Court holds that
petitioner is not entitled to a dependency exemption deduction
for his daughter for 2000.
Deduction for Medical Expenses
Petitioner argued at trial that he should be allowed medical
expense deductions for himself and amounts he spent for medical
insurance on his children. He alleges that he incurred as a
medical expense for himself less than $100 for anger management
counseling from a person named Dolly Powell. He testified that
he was unable to obtain any information from her and that her
telephone number is unpublished.
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
sufficient to provide some basis upon which an estimate may be
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