Michael D. and Christine R. Alexander - Page 18

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          tasks other than routine family chores, the time sheet does not             
          provide a reasonable basis for applying the Cohan rule.  See                
          Vanicek v. Commissioner, 85 T.C. at 742-743.                                
               On the basis of all of the facts and circumstances, we                 
          conclude that the payments to the daughters represent personal,             
          living, or family expenses.  See sec. 262(a).  Petitioners failed           
          to issue Forms W-2 and predetermined the amounts they would pay             
          their daughters.  The daughters’ tasks were mostly in the nature            
          of routine family chores, and there was a lack of correlation               
          between the payments they received and the hours they worked.               
          Accordingly, petitioners cannot deduct the payments to their                
          daughters as wage expense.  Respondent’s determination is                   
          4.   Estoppel                                                               
               Petitioners contend that at some point before or during                
          1998, they spoke to an employee of the Internal Revenue Service             
          (IRS) concerning their plan to hire their children as employees.            
          Petitioners contend the IRS employee indicated that petitioners             
          could deduct the compensation paid to their children.                       
          Petitioners thus appear to argue that respondent is estopped from           
          disallowing their claimed deductions.                                       
               Equitable estoppel is a judicial doctrine that precludes a             
          party from denying his own acts or representations which induced            
          another to act to his detriment.  Hofstetter v. Commissioner, 98            

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