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development of the business. Commissioner v. Heininger, 320 U.S.
467, 471 (1943).
The breadth of section 162(a) is tempered by the requirement
that any amount claimed as a business expense must be
substantiated, and taxpayers are required to maintain records
sufficient therefor. Sec. 6001; Hradesky v. Commissioner, 65
T.C. 87, 89-90 (1975), affd. 540 F.2d 821 (5th Cir. 1976); sec.
1.6001-1(a), Income Tax Regs. When a taxpayer adequately
establishes that he or she paid or incurred a deductible expense
but does not establish the precise amount, we may in some
circumstances estimate the allowable deduction, bearing heavily
against the taxpayer whose inexactitude is of his or her own
making. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.
1930). There must, however, be sufficient evidence in the record
to provide a basis upon which an estimate may be made and to
permit us to conclude that a deductible expense, rather than a
nondeductible personal expense, was incurred in at least the
amount allowed. Williams v. United States, 245 F.2d 559, 560
(5th Cir. 1957); Vanicek v. Commissioner, 85 T.C. 731, 742-743
(1985).
Furthermore, business expenses described in section 274 are
subject to rules of substantiation that supersede the doctrine of
Cohan v. Commissioner, supra. Sanford v. Commissioner, 50 T.C.
823, 827-828 (1968), affd. 412 F.2d 201 (2d Cir. 1969); sec.
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