- 9 - See Boyd v. Commissioner, 122 T.C. 305, 320 (2004); Watson v. Commissioner, T.C. Memo. 1988-29. During petitioner’s testimony, he contradicted himself, admitted to errors in the Schedules C relative to expenses, and in some instances could not recall what the claimed expenses were. Further, petitioner did not make a good faith effort to reconstruct his expenses, provide documentation, or provide corroborating evidence to bolster the credibility of his testimony. See Tokarski v. Commissioner, supra at 77; Smith v. Commissioner, T.C. Memo. 1998-33. Therefore, the Court finds petitioner’s testimony was insufficient to substantiate his deductions. Boyd v. Commissioner, supra; Watson v. Commissioner, supra. Finally, petitioner failed to reconstruct his records, submit any documentation, or otherwise provide sufficient evidentiary basis for the Court to estimate his expenses under the Cohan rule. See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). Therefore, the Court sustains respondent’s determination disallowing petitioner’s Schedule C expenses of $46,669, $44,451, $44,063, and $39,135 for 1998, 1999, 2000, and 2001, respectively. As a result of the above, the Court sustainsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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