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deductible expenses have been incurred. However, there must be
sufficient evidence in the record to provide a basis for making
an estimate. Mendes v. Commissioner, 121 T.C. 308 (2003);
Vanicek v. Commissioner, 85 T.C. 731, 742-743 (1985). This is
not a case where no allowance has been made for the costs of
relocating the Culinary facility, and a substantial amount has
been conceded by respondent. Approximations under the Cohan rule
necessarily bear heavily upon taxpayers whose inexactitude in
failing to keep records created the problem. See Cohan v.
Commissioner, 39 F.2d at 544. Here there is evidence that
certain payments were made and recorded. From that, petitioner
asks us to conclude that the payments must have been either for
deductible expenses or depreciable assets and that the
expenditures that were made are attributable to a tax year before
the Court.
The only evidence that petitioner produced in this regard
was the list of vendors and amounts that were recorded in the
moving expenses account and the testimony of David L. Van Bebber
(Van Bebber), a lawyer involved in the Culinary acquisition who
had reviewed the document and concluded that “This lists out
certain third party vendors that I believe Culinary was utilizing
or making payments to for goods or services.” Van Bebber was
familiar with some, but not all, of the vendors on the list. As
to one, for example, he testified that “It could be line
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