- 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 sustains
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