Karen V. Hough - Page 13

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          11.  Expenses Allowed or Conceded by Respondent                             
               Respondent has allowed or conceded other items, such as                
          telephone expenses and legal expenses, up to the amounts of                 
          checks or receipts previously provided by petitioner.  As there             
          is insufficient evidence to establish a rational basis for making           
          an estimate of a greater amount, we shall not allow petitioner a            
          deduction for these items greater than that allowed or conceded             
          by respondent.  See Cohan v. Commissioner, supra at 543-544;                
          Vanicek v. Commissioner, supra at 742-743.                                  
               To reflect the foregoing,                                              


                                                  Decision will be entered            
                                             under Rule 155.                          
























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