- 12 - no evidence to support the claimed deduction for the purchase of tax preparation software. As discussed supra, when a taxpayer establishes that he has incurred a deductible expense but is unable to substantiate the exact amount, the Cohan doctrine permits the Court to estimate the deductible amount. Cohan v. Commissioner, 39 F.2d at 543- 544. The Court must, however, have a reasonable basis upon which an estimate can be made. Vanicek v. Commissioner, 85 T.C. at 742-743. Because the record contains no evidence upon which we could base an estimate, we conclude that petitioner is not entitled to the remaining $125 deduction claimed for tax preparation fees, and respondent’s determination with regard to this amount is sustained. To reflect the foregoing and the concessions made by the parties, Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13Last modified: November 10, 2007