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5. Books
Petitioner claimed zero for books on her 2000 return.
Respondent, however, allowed petitioner at audit $1,870 for book
expenses for 2000. Ms. Babyak testified that petitioner bought
books for Ms. Babyak in 2000, but there is no evidence regarding
the cost of the books. As there is insufficient evidence to
establish a rational basis for making an estimate, petitioner is
not entitled to a deduction greater than that allowed by
respondent for books for 2000. See Cohan v. Commissioner, 39
F.2d at 543-544; Vanicek v. Commissioner, 85 T.C. at 742-743.
6. Supplies
Petitioner claimed $1,359 and $20,997 for supplies for 1999
and 2000, respectively. Respondent allowed $1,724.98 and $2,179
for supplies for 1999 and 2000, respectively. Although Ms.
Babyak testified that petitioner bought various supplies in 2000,
there is no evidence regarding the cost of the supplies or that
the amount spent exceeds the amount allowed by respondent. As
there is insufficient evidence to establish a rational basis for
making an estimate, we shall not allow petitioner a deduction for
these items greater than that allowed by respondent for supplies
for 1999 and 2000. See Cohan v. Commissioner, supra at 543-544;
Vanicek v. Commissioner, supra at 742-743.
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