context: This circuit's precedents adopting the Cohan rule, however, are clear that the rule does not obviate the need for some proof of entitlement to a deduction in the first place. The finding of the Tax Court that Sparkman failed to establish such an entitlement eliminates the requirement that the Tax Court estimate what those losses were.
citation_a.signal: see
citation_a.identifier: 829 F.2d 828, 831
citation_a.parenthetical: summarizing Cohan as standing for the proposition that "a court should allow the taxpayer some deductions if the taxpayer proves he is entitled to the deduction but cannot establish the full amount claimed" (emphasis added
citation_a.sentence: See Edelson v. Comm’r, 829 F.2d 828, 831 (9th Cir.1987) (summarizing Cohan as standing for the proposition that “a court should allow the taxpayer some deductions if the taxpayer proves he is entitled to the deduction but cannot establish the full amount claimed” (emphasis added)); see also Norgaard v. Comm’r, 939 F.2d 874, 879 (9th Cir.1991) (noting that, under the Cohan rule, the trial court “may not be compelled to guess or estimate ... even though such an estimate, if made, might have been affirmed”).
citation_b.signal: see also
citation_b.identifier: 939 F.2d 874, 879
citation_b.parenthetical: noting that, under the Cohan rule, the trial court "may not be compelled to guess or estimate ... even though such an estimate, if made, might have been affirmed"
citation_b.sentence: See Edelson v. Comm’r, 829 F.2d 828, 831 (9th Cir.1987) (summarizing Cohan as standing for the proposition that “a court should allow the taxpayer some deductions if the taxpayer proves he is entitled to the deduction but cannot establish the full amount claimed” (emphasis added)); see also Norgaard v. Comm’r, 939 F.2d 874, 879 (9th Cir.1991) (noting that, under the Cohan rule, the trial court “may not be compelled to guess or estimate ... even though such an estimate, if made, might have been affirmed”).