Carl F. and Frances R. Butler - Page 9

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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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