Ibrahim Keita - Page 13
- 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
Decision will be entered
under Rule 155.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: November 10, 2007