-12- evidence to that effect is petitioner’s own self-serving testimony, which we do not find to be credible. Id. Finally, with respect to the office, bad debt, advertising, and taxes and licenses expenses, petitioner vaguely described what he incurred. Petitioner did not, however, introduce any documentation to show the amount of any of these expenses. For the insurance, interest, depreciation, and legal and professional expenses, petitioners offered nothing. We conclude that petitioners failed to substantiate any repair and maintenance, supplies, bad debt, office, insurance, interest, depreciation, advertising, taxes and licenses, and legal and professional expenses, and thus they are not entitled to any deduction beyond what respondent previously allowed. No additional amount may be estimated under the Cohan rule because there is no basis to do so. See Vanicek v. Commissioner, supra at 742-743. II. Section 274(d) Expenses We turn next to the business expenses that are subject to the strict substantiation requirements of section 274(d). In addition to the general substantiation requirements, taxpayers must substantiate certain business expenses, such as car and truck, travel, and meals and entertainment expenses, by adequate records or by sufficient evidence corroborating the taxpayer’s own statement. Sec. 274. The substantiation must show thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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