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least some reasonable evidence from which to estimate a
deductible amount. Vanicek v. Commissioner, 85 T.C. 731, 743
(1985).
Other than the handwritten check log and petitioner’s
unsupported testimony, there is nothing in the record to show
that the alleged expenses were actually incurred. The record is
insufficient to provide the Court with a reasonable evidentiary
basis for estimating the deductible amount. Therefore, we find
that we may not use the Cohan rule to estimate petitioner’s
allowable expenses. We hold that petitioner is not entitled to
any deductions beyond the personal exemption and the standard
deduction already allowed by respondent. As a result, except to
the extent conceded, respondent’s determination that petitioner
has a Federal income tax deficiency of $17,165 in 2000 is
sustained.
D. Additions to Tax Under Sections 6651(a)(1) and 6654(a)
Finally, we must determine whether petitioner is liable for
additions to tax under sections 6651(a)(1) and 6654(a).
Respondent bears the burden of production with respect to
petitioner’s liability for the additions to tax. Sec. 7491(c);
Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001). To meet
his burden of production, respondent must come forward with
sufficient evidence indicating that it is appropriate to impose
the additions to tax. Higbee v. Commissioner, supra at 446-447.
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