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interest” ($1,877.96) plus the a loan origination fee ($611.50)
plus the broker discount ($2,446) equals $4,935.46. The $5.46
difference is probably attributable to the declining amount of
interest charged as the principal of the mortgage was paid down.
Accordingly, we conclude that the settlement statement is
insufficient evidence to allow petitioner a deduction greater
than the $4,930 respondent allowed.
Petitioner testified that he paid mortgage interest on a
house other than the house he purchased in Monument, Colorado.
Petitioner presented no documentary evidence to support this
assertion.
When a taxpayer establishes that he has incurred deductible
expenses but is unable to substantiate the exact amounts, we can
estimate the deductible amounts, but only if the taxpayer
presents sufficient evidence to establish a rational basis for
making the estimates. 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 amounts allowable, we bear
heavily upon the taxpayer whose inexactitude is of his own
making. See Cohan v. Commissioner, supra at 544.
Petitioner relies on his own testimony. The Court is not
required to accept petitioner’s unsubstantiated testimony. See
Wood v. Commissioner, supra at 605. We found petitioner’s
testimony to be general, vague, and conclusory. Under the
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