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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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