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vague, conclusory, and/or questionable in certain material
respects. Under the circumstances presented here, we are not
required to, and do not, rely on petitioner’s testimony to
sustain her burden of establishing error in respondent’s
determinations. See Lerch v. Commissioner, 877 F.2d 624, 631-632
(7th Cir. 1989), affg. T.C. Memo. 1987-295; Geiger v.
Commissioner, 440 F.2d 688, 689-690 (9th Cir. 1971), affg. per
curiam T.C. Memo. 1969-159; Tokarski v. Commissioner, 87 T.C. at
77.
Petitioner also presented the testimony of Don Monson. Mr.
Monson’s testimony related to petitioner’s alleged law library.
Mr. Monson testified that around 1980 he visited Mr. Ludlow’s
office and saw that he had an extensive law library. When a
taxpayer establishes that she has incurred deductible expenses
but is unable to substantiate the exact amounts, we can estimate
the deductible amount, but only if the taxpayer presents
sufficient evidence to establish a rational basis for making the
estimate. See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d
Cir. 1930); Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985).
In estimating the amount allowable, we bear heavily upon the
taxpayer whose inexactitude is of her own making. See Cohan v.
Commissioner, supra at 544.
Petitioner has not provided sufficient evidence to establish
a rational basis for estimating the amount of her Schedule C
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