- 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.
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