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(Nov. 6, 1985). In these instances, the Court is permitted to
make as close an approximation of the allowable expense as it
can, bearing heavily against the taxpayer whose inexactitude is
of his or her own making. Cohan v. Commissioner, supra at 544.
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, supra at 742-743. Without
such a basis, any allowance would amount to unguided largesse.
William v. United States, 245 F.2d 559, 560-561 (5th Cir. 1957).
The record provides no satisfactory basis for estimating
petitioner’s gambling losses. See Stein v. Commissioner, supra.
Unlike cases such as Doffin v. Commissioner, T.C. Memo. 1991-114,
where evidence of the taxpayer’s lifestyle and financial position
allowed this Court to approximate unsubstantiated gambling
losses, petitioner has failed to produce any evidence to
corroborate her story.4 Consequently, the Court will not apply
the Cohan rule to estimate the amount of petitioner’s gambling
losses.
4 Petitioner asserted at trial that the difference between
her gambling income and the loss she substantiated was put back
into slot machines. This testimony, standing by itself, does not
constitute a basis which would allow us to approximate
petitioner’s gambling losses.
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