Otu and Carol Obot - Page 7

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               Taxpayers may meet their burden even without proof of                  
          precise numbers.  If a taxpayer claims a business expense, but              
          cannot fully substantiate it, we may approximate the allowable              
          amount.  Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.               
          1930).  For this rule to apply, the taxpayer must provide at                
          least some reasonable evidence from which to estimate a                     
          deductible amount.  Vanicek v. Commissioner, 85 T.C. 731, 742-743           
          (1985).  We need not apply the Cohan rule at all if the evidence            
          is insufficient to identify the nature or estimate the extent of            
          the expenses.  See Williams v. United States, 245 F.2d 559, 560             
          (5th Cir. 1957).  Because the evidence Mr. Obot provided lacks              
          credibility, we will not use the Cohan rule in recalculating his            
          deductions.  See Lerch v. Commissioner, 877 F.2d 624, 628-629               
          (7th Cir. 1989) (no obligation to apply Cohan rule where taxpayer           
          fails to cooperate with Commissioner and Tax Court), affg. T.C.             
          Memo 1987-295.                                                              
               With these general thoughts in mind, we now look to each of            
          the disputed deductions.                                                    
          Schedule A                                                                  
               The disputed Schedule A deductions are taxes that Mr. Obot             
          paid.  The first group are excise taxes of $1,021 charged on his            
          personal utility, telephone, gasoline, and sewer bills.  Excise             
          taxes on personal bills are not deductible, Fife v. Commissioner,           
          73 T.C. 621, 623-624 (1980), and we disallow them.                          






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