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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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