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failed to substantiate that any additional amounts were paid for
insurance for 1999 or 2000.3
3. Dues and Memberships
Petitioner claimed $2,204 and $2,504 in expenses for dues
and memberships for 1999 and 2000, respectively. Respondent
allowed $800 for 1999 and disallowed this expense in full for
2000.
Ms. Babyak credibly testified that in 2000 petitioner paid
approximately $300 each for dues and memberships to approximately
four to five nursing societies/agencies. On the basis of the
record, we approximate that petitioner paid $1,200 in 2000 for
dues and memberships and is entitled to deduct this amount for
2000. Petitioner has failed to substantiate that any additional
amounts were paid for dues and memberships for 1999 or 2000.
4. Fed Ex and P.O. Box (Postage and Delivery Expenses)
Petitioner claimed $7,204 for postage for 1999, $15,023 in
delivery and freight expenses for 2000, and $360 for P.O. box
3 Petitioner claimed she paid $1,800 for flood insurance.
Ms. Babyak testified that petitioner paid flood insurance, but
she did not testify as to the amount paid. We do not rely on
petitioner’s testimony to establish the amount paid for flood
insurance. As there is insufficient credible evidence to
establish a rational basis for making an estimate, we shall not
allow petitioner a deduction for flood insurance. See Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Vanicek v.
Commissioner, 85 T.C. 731, 742-743 (1985). Additionally,
petitioner claimed she paid disability insurance. We do not
accept petitioner’s unsubstantiated and uncorroborated testimony.
See Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir. 1964),
affg. 41 T.C. 593 (1964).
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