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taxpayer whose inexactitude in substantiating the amount of the
expense is of his own making, and allow the deduction to that
extent. Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930).
However, in order for the Court to estimate the amount of an
expense, the Court must have some basis upon which an estimate
may be made. Vanicek v. Commissioner, 85 T.C. 731, 742-743
(1985). Without such a basis, any allowance would amount to
unguided largesse. Williams v. United States, 245 F.2d 559, 560-
561 (5th Cir. 1957). With these well-established propositions in
mind, we must determine whether petitioners have satisfied their
burden of proving that they are entitled to the claimed expenses
mentioned above.
1. Medical and Dental Expenses
As previously stated, on their Schedule A for taxable year
2002, petitioners claimed a deduction of $10,723 for medical and
dental expenses incurred during taxable year 2002. Respondent,
at trial, conceded that petitioners substantiated medical and
dental expenses incurred during taxable year 2002 of $4,468.
However, respondent notes that petitioners did receive
reimbursement from the National Children’s Cancer Society, Inc.
for medical expenses paid relating to Carla of $1,180, which
would decrease any deduction allowed for medical and dental
expenses paid. Further, respondent contends that petitioners
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