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7. Pest Control and Lawn Service
Petitioner claimed $770 for pest control for 2000 and at
trial claimed she also paid for lawn service. Respondent
disallowed the amount claimed for pest control in full. Although
Ms. Babyak testified that petitioner paid for pest control and
lawn service in 2000, there is no evidence regarding the cost of
the pest control and lawn service. As there is insufficient
evidence to establish a rational basis for making an estimate, we
shall not allow petitioner a deduction for these items. See
Cohan v. Commissioner, supra at 543-544; Vanicek v. Commissioner,
supra at 742-743.
8. Advertising/Marketing
Petitioner claimed $6,234 and $3,063 in expenses for
advertising for 1999 and 2000, respectively. Respondent allowed
$1,560.60 and $5,580.91 for 1999 and 2000, respectively.
Respondent conceded an additional $3,395 for 2000 (for a total of
$8,975.91 for 2000).
Ms. Babyak testified that petitioner mailed marketing
packages during 2000. Ms. Babyak’s testimony, however, did not
establish the cost of the marketing packages or how many were
mailed. We do not accept petitioner’s unsubstantiated and
uncorroborated testimony as to the cost of these marketing
packages or the amount mailed. See Wood v. Commissioner, 338
F.2d at 605. It is unclear whether petitioner spent amounts on
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