cohan rule estimates not permitted

Id. There is some support in endstream endobj startxref Reviewing bank account statements, canceled checks, and credit card statements. sections. The Cohan rule gives taxpayers a number of options beyond providing receipts for demonstrating that money was spent on business operations, but it will require a bit of effort on your part. For example, the Cohan rule does not apply to items that are listed in, Section 274(d) of the Internal Revenue Code. The Cohan Rule explicitly states that a court can "bear heavily if it chooses on a taxpayer whose inexactitude is of his own making." Good examples of this premise in action are Harlan, T.C. In contrast, the Tax Court had historically demonstrated some limited leniency in the area of charitable donations, allowing estimates or allocations justified, explicitly or implicitly, byCohan[see, e.g.,Fontanilla v. Commr, T.C. However, if you have no receipts, the IRS will not allow you to deduct the full amount of your expenses. The issue of missing or lost receipts is so common that in 1930 the United States Court of Appeals For the Second Circuit outlined a rule on how the IRS should proceed in those situations. professional call as to when, if ever, estimates may be relied [8] Vanicekv.Commissioner,85T.C. Mr. Freeman was named the Leading Tax Controversy Litigation Attorney of the Year for the State of Texas for 2019 and 2020 by AI. [13], The Tax Court has applied the Cohan rule to estimate the basis of stock. Consequently, CPAs are often forced to prepare returns based on estimates. document.write(''); if (!window.AdButler){(function(){var s = document.createElement("script"); s.async = true; s.type = "text/javascript";s.src = 'https://servedbyadbutler.com/app.js';var n = document.getElementsByTagName("script")[0]; n.parentNode.insertBefore(s, n);}());} g1>co!i"L 1990). 1969);Noz v. Commr, T.C. (2d Cir. You may have access to different export options including Google Drive and Microsoft OneDrive and citation management tools like RefWorks and EasyBib. when records are missing or incomplete, Temp. The rule was adopted and laid down in the US by the Second Circuit in the case titled Cohan v. Commissioner, hence the name of the rule. no receipts. CPAs should refer to AICPA Statement on Standards for Tax Oops! Finally, even outside its original context (i.e., inadequately documented business deductions), Cohan continues to be important because courts have relied on it to permit estimates in a variety of You have requested "on-the-fly" machine translation of selected content from our databases. Memo. [SeeBuelow v. Commr, 970 F.2d 412, 415 (7th Cir. $.' [29] These strict rules generally require that a taxpayer substantiate with adequate records or by sufficient evidence corroborating the taxpayers own statement: (1) the amount of the expense; (2) the time and place the expense was incurred; (3) the business purpose of the expense; and (4) in the case of an entertainment expense, the business relationship between the person entertained and the taxpayer. In recent years the IRS has been more likely to audit taxpayers with a taxable income of more than $1 million annually. It only allows a court (not the taxpayer) to determine a reasonable deduction. rule is anything but certain. Memo. Without some documentation, the Cohan rule doesn't help you. This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction. var plc461032 = window.plc461032 || 0; 491 0 obj <> endobj to the credit because he had failed to substantiate his claim. 2017-140, at *7; sec. Tax Court concluded that the taxpayer could not use general Enter Cohan vs. Commissioner, 39 F. 2d 540 (2d Cir. 2005-157 and Stewart, T.C. But records and documents are still occasionally lost, destroyed, purged, or otherwise difficult for the taxpayer to find or access. (CCH) 63 (T.C. [9] Moreover, even a successful application may not yield the result some taxpayers anticipate. 6695 (miscellaneous preparer penalties), Sec. George Cohan (Petitioner) was a theatrical manager, known for his contributions to Broadway and his over-the-top entertaining of both fans and critics. <>/Metadata 912 0 R/ViewerPreferences 913 0 R>> This worked well for the taxpayers inArmando Sandoval Lua v. CommissionerTC Memo 2011-19in that the taxpayers provided sufficient evidence demonstrating additional compensation expense was incurred for additional services provided even though it was in the form of cash. frequently lose, this makes the use of estimates a very The rule was outlined in the court's decision in Cohan v. 41 research credit regulations (function(){ All rights reserved. You should have a CPA, enrolled agent, or tax attorney to accompany you for the interview with these types of audits. Luckily for Cohan, his case (function(){ C.I.R., 35 T.C.M. These penalties require the preparer to make a AdButler.ads.push({handler: function(opt){ AdButler.register(165519, 461033, [300,600], 'placement_461033_'+opt.place, opt); }, opt: { place: plc461033++, keywords: abkw, domain: 'servedbyadbutler.com', click:'CLICK_MACRO_PLACEHOLDER' }}); This is primarily the result of the IRSs claims that most tax cheats are self-employed individuals who have either not claimed all their income or claimed tax deductions they were not eligible to take. 6 0 obj 1976) (to allow the Cohan doctrine to be invoked by the taxpayers wouldbe in essence to condone the use of that doctrine as a substitute for burden of proof. The Cohan rule is derived from the Second Circuits 1930 decision, Cohan v. Commissioner, which allowed the taxpayer to approximate travel and entertainment expenses in the absence of records indicating an exact amount. During filing season, tax preparers will inevitably confront the question of how to report items for which a taxpayer lacks sufficient (or even any) documentation. However, relying on the Cohan The court was not persuaded to use the travel records the taxpayer created only after IRS notification of examination, holding while a contemporaneous log is not required to substantiate the deduction, a taxpayers subsequent reconstruction of his or her expenses does require corroborative evidence with a high degree of probative value to support such a reconstruction, in order to elevate that reconstruction to the same level of credibility as a contemporaneous record (Franklin, at 13-14). var abkw = window.abkw || ''; Please email support@keepertax.com if you have questions. (Court disallowed nearly $7,000 in deductions due to missing sufficient detail for the court to objectively estimate a value.), The Cohan Rule: Tax Deductions with Incomplete Records, Partnership Representatives and BBA Resources, Cryptocurrency and Blockchain Law Resources. 1997-487;Cavalaris v. Commr, T.C. This is usually the result of the taxpayer omitting income from his or her return or making a serious error. The translations are automatically generated "AS IS" and "AS AVAILABLE" and are not retained in our systems. The Statute of Limitations for Receipts [10] See Reese v. var AdButler = AdButler || {}; AdButler.ads = AdButler.ads || []; AdButler.ads.push({handler: function(opt){ AdButler.register(165519, 459496, [300,600], 'placement_459496_'+opt.place, opt); }, opt: { place: plc459496++, keywords: abkw, domain: 'servedbyadbutler.com', click:'CLICK_MACRO_PLACEHOLDER' }}); Sam Kong Fashions, Inc., T.C. 4, Use of Estimates. It is important to note that the regulations do not allow for a re-creation of the expense log without sufficient supporting evidence. We want to hear from you. 55 The Cohan rule allows courts to make estimates where there is some indication that the taxpayer is entitled to the tax deduction or credit. Under certain circumstances, a court may waive this requirement and allow the use of a deduction estimate. Association of International Certified Professional Accountants. The decision still stands - direct records are not needed to verify an IRS expense deduction. var absrc = 'https://servedbyadbutler.com/adserve/;ID=165519;size=300x600;setID=494109;type=js;sw='+screen.width+';sh='+screen.height+';spr='+window.devicePixelRatio+';kw='+abkw+';pid='+pid494109+';place='+(plc494109++)+';rnd='+rnd+';click=CLICK_MACRO_PLACEHOLDER'; 5 0 obj totally if a taxpayer does not have all the records required Under the Cohan rule, the court can approve deductions if it's convinced that expenses were actually incurred, even if the records don't measure up. Your submission has been received! v. the addition of Sec. See Cohan, 39 F.2d at 544. var plc461033 = window.plc461033 || 0; For instance, in var pid494109 = window.pid494109 || rnd; Thank you! PDF The Cohan Rule An IRS Audit Defense Tool - IRS tax forms All rights reserved. So a few years may go by between the time you filed a return and when you will need to show your receipts for the tax year in question. The Cohan Rule is a discretionary standard and can be used to support a reasonable estimate of compliance requirements." This worked well for the taxpayers in Armando Sandoval Lua v. Commissioner TC Memo 2011-19 in that the taxpayers provided sufficient evidence demonstrating additional compensation expense was incurred for additional . As the above discussion demonstrates, theCohanrule can be a useful tool for taxpayers in a variety of circumstances; CPAs, however, should remember the rules proper application and its limitations. Cohan Rule | RJS LAW | Tax Attorney | San Diego var abkw = window.abkw || ''; Keeper is. For example, if you claim $1,200 worth of office supplies, you cannot simply say that you . endstream Finally,Cohanis of no use to the taxpayer when recordkeeping requirements are statutorily or regulatorily imposed, such as in IRC Section 274 (establishing specific substantiation requirements with respect to a variety of expenses such as travel, meals, and gifts) and IRC section 170 (allowing a charitable contribution deduction). 1981-176]. Charron v. United States, 200 F.3d 785 (Fed. It allows taxpayers to deduct expenses for business even if they do not have the receipts to document them. vc^fvz? A taxpayer may not rely on theCohanrule where statutory or regulatory provisions specifically establish substantiation requirements. var pid289809 = window.pid289809 || rnd; ICYMI | A Practical Roadmap for Introducing Agility to Certified Public Accounting, ICYMI | Practice Management and Tax Practice in the Current Environment, ICYMI | Seven Ways to Decrease Stress at Work, Tax Changes in the Inflation Reduction Act of 2022, Why CPAs Misfire in Personal Financial Planning, Tax Software in the Ongoing Pandemic Environment, Technostress and the Accounting Profession, Cybersecurity Resources for Accounting Practices, ICYMI | A Practical Roadmap for Introducing Agility to Certified Public Accounting Firms. responsibility to clients to consider estimates while 08-20377 (5th Cir. Sec. the taxpayer failed to make efforts to reconstruct the records var plc459496 = window.plc459496 || 0; The Second Circuit found that it was clear that Cohan had incurred some expenses, even if he could not substantiate the exact amounts. Reasonableness Standard The Service and the courts agree that strict proof of otherwise deductible business expenses are not always available or attainable. Try and log in through your institution to see if they have access to the full text. 1J:kan*}>r8"GC6&-Cl@v[i"jr!F r`XCs9YvP?Zs"h* g@L!0%0(I.RA ED)8Ocm8*ULxT4(9i;GN[1QL Patents, patent applications, and copyrights. After failing to keep atop his substantial Broadway expenditures, Mr. Cohan offered for the courts approval his tax code debut. In the business deduction context, the taxpayers threshold burden is evidentiary. (Cohan Rule could not be applied to utility expenses because the taxpayer did not substantiate them and did not offer any evidence that the expenses could be reasonably apportioned). Field Audits. that included the credit. [7] Rodman v. Commissioner [762 USTC 9710], 542 F.2d 845, 854 (2nd Cir.1976) ([r]egardless of theCohanrule with respect toamountsallowable, the courts have consistently held that at least theexistenceof an expense must be proved before any deduction can be taken.)(Emphasis in original). We want to hear from you. Granted, this means the taxpayer is at the On appeal, the Fifth Circuit reversed the district court's decision, noting that the district court should have applied the Cohan rule once it determined that there were some QRAs. In order to get full access, you need to be on campus or log in through your institution ().. 1969). [1] The rule has since stood for the proposition that, with some exceptions, taxpayers who are unable to produce complete records may nonetheless be allowed to estimate certain tax deductions. hYms6/g:KZ4r?,L*IvD9,}vqfcLur,WKf#bB*Ia-,LFB38B ,&%pfp.agIiH.0>_8_\AhWpXL4L\]>i.gI8%qcF:?_ysBQz(^qpe1U,f{vd8-i^m9;?a{.NEs4+} 0LBb{O*644t|/M7U;j+>Y4$>OjfIR|]f$AyoRI0,&I2-FPeI5? What should the preparer do on original 1930) Taxpayers in this position face a two-pronged hurdle: First, the taxpayer must demonstrate the existence or fact of the claimed expense. The IRS can, and often does, disallow deductions based on the taxpayer's failure to properly document or substantiate the deduction in non-IRC section 274 circumstances. John Miller is a faculty instructor at %%EOF 179D energy-efficient commercial buildings deduction, IRS provides guidance on perfecting S elections and QSub elections. var absrc = 'https://servedbyadbutler.com/adserve/;ID=165519;size=300x600;setID=289809;type=js;sw='+screen.width+';sh='+screen.height+';spr='+window.devicePixelRatio+';kw='+abkw+';pid='+pid289809+';place='+(plc289809++)+';rnd='+rnd+';click=CLICK_MACRO_PLACEHOLDER'; 1971). <> the expenses associated with those activities, despite the research credits if the taxpayer can prove that it incurred var absrc = 'https://servedbyadbutler.com/adserve/;ID=165519;size=300x250;setID=228993;type=js;sw='+screen.width+';sh='+screen.height+';spr='+window.devicePixelRatio+';kw='+abkw+';pid='+pid228993+';place='+(plc228993++)+';rnd='+rnd+';click=CLICK_MACRO_PLACEHOLDER'; var divs = document.querySelectorAll(".plc461033:not([id])"); sued McFerrin for return of the refund on the grounds that PDF Additional Requirements for Appeals Access and Compressed Case %PDF-1.6 % 1957) (emphasis in original)]. In the words of the Cohan court, "absolute certainty in such matters is usually impossible" and it is "not fatal that such results will inevitably be speculative; many important decisions must be such." [6] The Cohan Rule, however, is not a free pass. It only applies when a taxpayer can demonstrate (to a courts satisfaction, if not the IRSs) that he incurred an expense but is unable to adequately document the amount thereof. Practical Documentation of QRAs for the R&D Tax Credit entitlement to business expense deductions. [34] 26 C.F.R. [24] Rogers v. Commr of Internal Revenue, 115 T.C.M. This article provides an overview of approximation in tax matters and notes where it has been limited by statute, regulations, and court decisions. Taxpayers have relied on theCohanrule for decades, most often to justify estimates of allowable business deductions. The appellate courts opinion is less than a model of clarity, yet it appears that the court was most influenced by the BTAs factual findings (i.e., the existence ofsomebusiness-related expenses): The question is how far this refusal [to allowanydeduction] is justified, in view of the finding that [Cohan] had spent much and that the sums were allowable expenses (Cohan, 39 F.2d, at 543). BRX>]8Pk0t2iMT!=HEm,]>eE&9cT:!#Eid{Zft&DP+nr'bj! )9w 3 0 obj It is a greataudit defense tool. What If I Get An IRS Tax Audit And I Have No Receipts? The Cohan Rule, as it is known, originated in the decision of Cohan v. Commissioner, 39 F.2d 540 (2d Cir. For donations of $250 or more, a contemporaneous written acknowledgement is required from the donee or its agent; a cancelled check alone is not sufficient [IRC Section 170(f)(8)(A); Treasury Regulations section 1.170A-13(f)(1)]. endobj document.write('<'+'div id="placement_459481_'+plc459481+'">'); [21] Id. taxpayers lack of substantiation. [28] In general, Section 274 limits or disallows deductions for certain meal and entertainment expenditures that otherwise would be allowable, primarily under Section 162(a) which allows a deduction for ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business. var abkw = window.abkw || ''; 2 0 obj Substantiation standards further derived from the Cohan rule have been held previously to deductions regarding legal fees,[23] interest,[24] stolen property,[25] and home offices. McFerrin was a well-known and respected chemical The Cohan Rule: Estimate Your Expenses For IRS Deductions $.' During filing season, tax preparers will inevitably confront the question of how to report items for which a taxpayer lacks sufficient (or even any) documentation. Knowledge is power. (CCH) 1232 (T.C. A corollary is that the IRS is under no obligation to estimateor accept a taxpayer's estimateunder Cohan. By using the site, you consent to the placement of these cookies. However, gamblers typically do not keep complete records of their gambling wins and losses. The Cohan rule, as it is known, is almost 70 years old, but it has withstood the test of time. rules suggests that the Service should not be arbitrary in First, the taxpayer must prove the existence of the expense by credible evidence; failure to do so naturally precludes any estimate of its amount. However, unless the IRS is alleging tax fraud or criminal activities, most are rather low-key affairs where agents ask the taxpayer for additional information and make adjustments to your tax bill or tax refund. While this documentation will show that the expense was legitimate, it rarely shows why the payment was made. Gain access through your school, library, or company. Rather than keep you waiting, we have only translated the first few paragraphs. which George M. Cohan, a great entertainer but a lousy var abkw = window.abkw || ''; Something went wrong while submitting the form. 1995-309, 1995 WL 412146, at *3 (stating that the Tax Court would not allow estimates when taxpayer documents were destroyed by a wind and hail storm and the taxpayer failed to make efforts to reconstruct the records),affd in part, revd in part on other grounds, 103 F.3d 138 (9th Cir. any, added disclosures are required. <>/XObject<>/Font<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 720 405] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> When common sense Perhaps the most common circumstance in which approximations are made is when the taxpayer is unable to substantiate the exact amount of a business deduction. If you are self-employed, you should know that you are more likely to have your individual tax returns audited by the Internal Revenue Service than your friends and family members who earn traditional Form W-2 income as employees. The taxpayer must provide sufficient evidence (documentary, testimonial, or other) showing that the taxpayer actually incurred an expense. Gifts over $5,000 require a qualified appraisal. In doing so, the Tax Court has said that the taxpayer needs to supply information to substantiate their claimed expenses. Random selection and computer screening. IRS Wants Receipts? This Tax Case Says They Are Optional - Forbes You may have access to it for free by logging in through your library or institution. One of the first cases to allow estimates in federal tax matters wasCohan v. Commr[39 F.2d 540 (2d Cir. Examples: State University, [emailprotected]. to IRS approval. Click the button below if you want to translate the rest of the document. If you believe that the findings were not in keeping with the evidence or the U.S. Tax Code, you can file an appeal that will be heard by an IRS appeals agent who will make a determination based on the facts of your case. For instance, As we discuss in greater detail below, theCohanrule cannot help a taxpayer who is unable to meet this threshold burden. engineer. div.id = "placement_461033_"+plc461033; about this column, contact Mr. Miller at johnmillercpa@cox.net. Jesus Morales is an Enrolled Agent and has 7 years of bookkeeping and tax experience. He has been credited with writing and publishing over 300 songs (including Youre a Grand Old Flag), over a dozen musicals, being a fabulous entertainer, networker, and generally credited with making Broadway into the global landmark it is today (see his statute and plaque in Manhattans famous Duffy Square). With that case, The Cohan Rule was established. Appx. hbbd``b`@HpA\,q b,Ay XDlq %$ O@BHH 1 2\h!crF% e [31] Cohan, at 544 (L. Hand, J.) 2005-212. courts have refused to apply the rule. The IRS often allows self-employed taxpayers to substantiate expenses throgh other means. 2020). (CCH) 1177 (T.C. The Cohan Rule in Action For further guidance, Cohan v. Commissioner, 39 F.2d 540 | March 3, 1930 | L. Hand, Circuit Judge | Docket No. Finally, the taxpayer must provide some basis upon which the IRS or a court can estimate the amount of the item. This article provides an overview of approximation in tax matters and notes where it has been limited by statute, regulations, and court decisions. G@M" ,P!S"Zi|& (u=1k\LJ}j _] <> By Randall Brody. PROQUEST AND ITS LICENSORS SPECIFICALLY DISCLAIM ANY AND ALL EXPRESS OR IMPLIED WARRANTIES, INCLUDING WITHOUT LIMITATION, ANY WARRANTIES FOR AVAILABILITY, ACCURACY, TIMELINESS, COMPLETENESS, NON-INFRINGMENT, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. According to the IRS, most tax returns selected for an income tax audit are chosen using two different methods: While the IRS will not specify exactly which factors it uses to determine which self-employed returns will be audited, most experts believe these items will raise red flags: Remember, the IRS has three years from when an income tax return was due or filed to impose additional taxes, whichever date is later. Use of a Deduction Estimate| The Cohan Rule | Tax Samaritan 7407 (action to enjoin tax return preparers), and other sections. 5 0 obj In these cases, the documentation itself is a requirement for the taxpayers entitlement to the item. For cash donations (including gifts by check or other monetary gifts), the taxpayer must retain either a cancelled check, receipt, or other reliable evidence [Treasury Regulations section 1.170A-13(a)(1)]. Memo 2019-90]. Ultimate Guide to Car Tax Deductions and Mileage, The Business Meal Deduction: A Freelancer's Guide. If the IRS chooses to allow some of the taxpayers claimed deduction in the face of incomplete or unconvincing evidence thereof, a court is unlikely to allow the taxpayer more than the IRS. var plc494109 = window.plc494109 || 0; iyW iMU 1930). income estimates when it had failed to keep adequate records var plc228993 = window.plc228993 || 0; The Cohan rule has been used in other R&D tax credit cases to estimate QREs in the absence of documentation of the exact amount of expenses. var abkw = window.abkw || ''; The Cohan rule still allows taxpayers to prove by "other credible evidence" that they actually incurred deductible expenses. In Cohan v. Commissioner of Internal Revenue, 39 F.2d 540 (2d Cir. Find answers to questions about products, access, use, setup, and administration. document.write(''); var rnd = window.rnd || Math.floor(Math.random()*10e6); [17] In William, the stock was valued, at the time of confiscation, at $1.5 million. ; Contact Us Have a question, idea, or some feedback? [Last updated in January of 2022 by the Wex Definitions Team], It must be noted that the Cohan rule does not have a universal applicability. Takes 30 sec after linking bank or credit card. <> 1 0 obj %A, Outside of the business deduction context, approximations are also often necessary for other tax items. 1930). Although the rule remains useful for tax preparers, it is limited, and its application varies by the taxpayer's circumstances. For. Estimating Tax Deductions: The Cohan Rule | TaxConnections whether they want to or not. [9] Coloman v. C. I. R., 540 F.2d 427, 432 (9th Cir. "Cohan Rule" Estimates - A Useful Tool if Properly Used IRS audits - how can you prove expenses without receipts? - IRS Tax Reviewing your calendar. [1] [29] See Gill v. United States, 296-81T, 1997 WL 820963, at *43 (Fed. var plc456219 = window.plc456219 || 0; In this circumstance, courts relying onCohanhave generally allowed the taxpayer a deduction in an amount the court deems reasonable based on the taxpayers limited documentation or their unsubstantiated testimony, albeit often less than the taxpayer originally claimed. strict compliance with documentation standards may not be 6695 (miscellaneous preparer penalties), Sec. Cohan appealed the IRS . (CCH) 933 (T.C. Cohan rule | Wex | US Law | LII / Legal Information Institute Therefore, if you have lost your receipts, you only be required to recreate a history of your business expenses at that time. b6 ITKvI20n`6031[ogd#q!$ ]8u8?:P7K30iidA0200 +@$ The classicCohansituation is the taxpayer who says, I know I spent some money. Njg6P3C/F62eOnJaW+jg0A==:oi2UEd16nCGmeFNE2pQuoASb33Mm2p0yk6ktClVhYGeDJvBVDczbC/U05Kgcffbn9gZZv9r1VkY0ybDHqZ4slBPgtNg8yQSY1I9yUJDt4AUPHJ97IAK94NmPwbawD5Ax9xyc48Yr+WDWrdkZvisfwkUlLaFdj4z/bZxiEI6msdDkZX4RurXtNdDWKytNqDtKRvqNqviOJPna7fcJSWERPuRKs628n8iZD6ksaJnICRbn3LgBDqsFQ0jjhgLXdJy4SDvsstrwW9lgxnRoSExyULJ9UIlQCjJ2gwiVq5xKkMVvFBvNEv9NyCRmHipcv9a58hCRKuRU2b3LmpBUH5DBCiicCqnlJcMABRtWdjTd5IqqI8/Pa4CmMpEWwp/R0TGLzsH67Mk0R6u/h1dkGnrLdw==. Tax preparers face sanctions for improperly using estimates, including the penalties under Sec. Sec. The cases cited above conclusively demonstrate that taxpayers must establish some reasonable grounds for estimation or allocation if they are to prevail. expenses but could not provide adequate records In all these circumstances, it is the taxpayers burden to prove the items existence and amount; conceptually at least, the failure to do so could wholly preclude the claimed tax benefit (i.e., deduction, basis, valuation). [4] The court then recognized that strict proof of otherwise deductible business expenses is not always available. Noncash property donations additionally require a receipt from the receiving organization showing the donees name and a description of the gifted property [Treasury Regulations section 1.170A-13(b)(1)]. Facing an IRS tax audit with missing receipts? [19] Furthermore, the basis granted was a significant reduction from the taxpayers estimate of $3 million and the Commissioners certified estimated loss of $9.5 million. 90 1978), affd, 629 F.2d 1160 (6th Cir. (Tax court allowed for deduction related to sale of coin collection.).

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