Kai-Chung C. and Meekhing T. Lam - Page 10

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          apply, however, a basis must exist on which this Court can make             
          an approximation.  Vanicek v. Commissioner, 85 T.C. 731, 742-743            
          (1985).  Without such a basis, any allowance would amount to                
          unguided largesse.  Williams v. United States, 245 F.2d 559, 560            
          (5th Cir. 1957).  Against this background, we consider the                  
          categories of expense for which there remain amounts in dispute.            
               First, petitioners contest respondent’s disallowance of                
          repair and maintenance expenses.  At trial, petitioner presented            
          documents regarding these expenses, all of which we find                    
          insufficient.  Almost all the documents submitted were invoices             
          rather than receipts.  While petitioner would have us believe               
          that receipts and invoices are one and the same thing, we                   
          disagree.  An invoice is a “written account of goods or services            
          to be provided,” while a receipt is a “writing acknowledging the            
          receiving of *** money.”  Webster’s New International Dictionary            
          1190, 1894 (3d ed. 1993).                                                   
               In addition to petitioner’s erroneous usage of invoices as             
          receipts, we find petitioner’s documents lacking in other                   
          respects.  Many of the documents are undated.  Petitioner assured           
          the Court that each of these expenses was properly claimed in the           
          year it was allegedly incurred because he found the documentation           
          in a box with other dated documents.  Yet petitioner offered no             
          testimony or evidence showing this record-keeping “system” was              
          free from error or manipulation.  Petitioner introduced some                






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