-10- 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 somePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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