Michael D. and Christine R. Alexander - Page 14

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          downstairs.  Prepare to paint.  9 hours”; (3) “Go rent rug                  
          shampooer.  Shampoo carpet sewing room.  9 hours”; (4) “Clean up            
          and vacuum.  4 hours”; and (5) “Go to San Francisco with mom to             
          help get wedding fabric.  8 hours.”  Each document indicates that           
          Steven worked 378 hours.                                                    
               It is not clear when petitioners prepared these documents or           
          whether they accurately reflect Steven’s hours, duties, and                 
          earnings.  Even if we accept the accuracy of the documents, many            
          of the tasks that Steven performed are in the nature of routine             
          family chores such as cleaning, vacuuming, taking out garbage,              
          and accompanying Mrs. Alexander on shopping trips.  Such chores             
          are “part of parental training and discipline rather than the               
          services rendered by an employee for an employer.”  Denman v.               
          Commissioner, supra at 450.                                                 
               Finally, we note that even if Steven performed tasks that              
          were not routine family chores, the schedule does not separately            
          identify the number of hours he spent on such tasks.  Where a               
          taxpayer establishes that he incurred a business expense but                
          cannot prove the amount of the expense, the Court may approximate           
          the amount allowable, bearing heavily against the taxpayer whose            
          inexactitude is of his own making.  Cohan v. Commissioner, 39               
          F.2d 540, 544 (2d Cir. 1930), affg. in part and remanding 11                
          B.T.A. 743 (1928); King v. Commissioner, T.C. Memo. 2006-112.  To           
          apply the Cohan rule, however, the Court must have a reasonable             

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