- 14 - expense is of his own making, and allow the deduction to that extent. Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930). However, in order for the Court to estimate the amount of an expense, the Court must have some basis upon which an estimate may be made. Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). Without such basis, any allowance would amount to unguided largesse. Williams v. United States, 245 F.2d 559, 560- 561 (5th Cir. 1957). With these well-established propositions in mind, we must determine whether petitioner has satisfied his burden of proving that he is entitled to the claimed Schedule C expenses. At trial, petitioner testified that most of his records substantiating his claimed Schedule C business expenses were destroyed due to a fire in his house. However, petitioner offered into evidence documents which were not destroyed by the alleged fire. These documents consisted of: (1) BellSouth phone bills which were in the name of and addressed to “Paula & Conrad Lewis Doing Business As Kiddy Cut & Style”, (2) utility bills from SCE&G in the name of and addressed to “Paula B. Adams[8] Doing Business As Kiddy Cuts & Style”, and (3) a letter from R.E. Hendrix - Apartment Rentals, stating: “This is to confirm the fact that Paula & Conrad Lewis rented from us unit N at Leesburg 8See footnote 3.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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