Karen V. Hough - Page 9

                                        - 9 -                                         
          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.                                  









Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011