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However, in cases where we have some basis to estimate a
taxpayer’s expenses, we are permitted to make an approximation.
Williams v. United States, 245 F.2d 559 (5th Cir. 1957) (stating
that the trier of fact must be satisfied by the evidence that the
estimated amount was spent or incurred for the stated purpose);
Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). The
approximation may bear heavily upon the taxpayer “whose
inexactitude is of his own making.” Id. at 544.
The record establishes that petitioner paid real estate
taxes and mortgage interest in connection with his residence in
the 1999 tax year. We can infer from the information returns and
the record that petitioner paid the two liabilities personally,
as he was the only member of his family with sufficient income to
cover these costs. Respondent did not argue that the mortgage
was never paid, nor did he present any evidence that someone
other than petitioner paid the mortgage. Instead, at trial,
respondent agreed to the amount of the mortgage interest paid in
1999. Petitioner is thus entitled to a deduction for his
mortgage interest paid. Turning to the real property taxes, the
only figure respondent and petitioner presented at trial related
to petitioner’s 2003 real property taxes. It is quite possible
that from 1999 (the year in issue) to 2003 petitioner’s home was
reappraised, altering his real property tax liability. Because
petitioner’s lack of diligence created this inexactitude, we find
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