Conrad Fitzgerald Lewis - Page 15

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          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             
               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.                                                            

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