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connection with a consulting business or any other trade or
business carried on by petitioner. Absent the stringent
substantiation requirements imposed by section 274, it is within
the purview of this Court to estimate the amount of allowable
deductions where there is evidence that deductible expenses were
incurred. See Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930).
Nevertheless, we must have some basis on which an estimate may be
made. Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985); see
also Norgaard v. Commissioner, 939 F.2d 874, 879 (9th Cir. 1991),
affg. in part and revg. in part T.C. Memo. 1989-390. Because the
record contains no evidence upon which we could base such an
estimate, we conclude that petitioner has failed to prove that he
is entitled to deduct any of the expenses reported on the
Schedule C. We allow no deduction for Schedule C expenses in the
computation of the deficiency resulting from this proceeding.
5. Schedule E Deductions
At issue is whether petitioner is entitled to any deduction
for the expenses set forth in our findings of fact, under the
heading “Schedule E Items”, in connection with the three rental
properties: 10 Park Ave., Apt. 8-B; Delray Racquet Club Condo
4303, and Delray Racquet Club Condo 9404 (together, the three
rental properties). The parties have jointly stipulated an
exhibit of 22 pages containing photocopies of bank checks and
other items that petitioner produced with respect to his claimed
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