-15- Commissioner, T.C. Memo. 2001-301; Joseph v. Commissioner, T.C. Memo. 1997-447. If the taxpayer claims a deduction but cannot fully substantiate it, we may estimate the allowable amount if there is sufficient evidence in the record to provide a basis for the estimate. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); see also Vanicek v. Commissioner, 85 T.C. 731, 742- 743 (1985). Petitioner failed to substantiate the business expenses and startup expenditures disallowed by respondent. At trial, petitioner introduced only a brief summary of expenses and two promissory notes purportedly issued as payment for professional services. None of those documents established the dates, description, or business purpose of the expenses. The evidence offered was completely inadequate to substantiate petitioner’s claimed expenses as required by section 6001 and related regulations. The complete absence of credible evidence in the record also precludes us from estimating petitioner’s expenses under Cohan. Petitioner did not offer testimony or documents to describe the nature and amount of the startup expenditures and business expenses that In Touch allegedly incurred during 2000, nor did petitioner offer the Court any credible explanation for InPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007