Ibrahim Keita - Page 13

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          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               

                                             Decision will be entered                 
                                        under Rule 155.                               

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Last modified: November 10, 2007