- 5 - failed to present any evidence of his deductions at the time of trial or during the month after trial that he was permitted to provide further information, after having received suggestions as to how his required records could be reconstructed. Although he relies on Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930), he provided no basis for making an estimate of deductions to which he might be entitled, which precludes our estimating such deductions. See, e.g., Mendes v. Commissioner, 121 T.C. 308, 316 (2003); Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). We have no reason to believe that petitioner’s allowable deductions exceeded the standard deductions allowed in the statutory notices of deficiency. Petitioner testified that he was divorced in 2002. There is no information in the record as to whether his former spouse filed tax returns for the years in issue. There is no evidence concerning any eligible dependents that he or his former spouse might have had. There is nothing in the record to contradict the “single” filing status used in the statutory notice for 2002. If petitioner was married in 2001, which is unclear from the record, he was not disadvantaged by the use of “single” status rather than “married filing separately”. On the other hand, respondent neglected to secure third- party records that corroborate the income set forth in the statutory notices. So far as the record reflects, despitePage: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007