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incurred in at least the amount allowed. Williams v. United
States, 245 F.2d 559, 560 (5th Cir. 1957). In estimating the
amount allowable, we bear heavily on the taxpayer whose
inexactitude in substantiating the amount of the expense is of his
own making. See Cohan v. Commissioner, supra at 544.
We are convinced that the Robco vehicles generated expenses
which, if substantiated, would be deductible by petitioners.
Robco vehicle expenses were reported in three different ways on
petitioners’ return: As a separate depreciation expense
deduction, as a separate insurance expense deduction, and as a
separate vehicle deduction based on the standard mileage rate.
Respondent correctly points out that the last of these deductions,
the deduction for vehicle expenses based on the standard rate, may
be used only in lieu of the first two. See sec. 1.274-5(j)(2),
Income Tax Regs.; Rev. Proc. 2001-54, 2001-2 C.B. 530. Therefore,
we must determine which, if any, of these deductions are
allowable; the three cannot be allowed together.
Section 167(a) allows a deduction for a reasonable allowance
for the exhaustion, wear and tear, and obsolescence of property
used in a trade or business or held for the production of income.
The basis on which a depreciation deduction is allowable with
respect to any property under section 167(a) is the adjusted basis
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