2025-04-11
Continuing our series on Famous Tax Quotes (quotes from court opinions and rulings with language that is colorful or that concisely states an important tax principle) today's tax quote is:
We find Rodriguez's testimony * * * to be credible * * *. We treat his testimony as an invocation of the rule of Cohan v . Commissioner, 39 F .2d 540, 544 (2d Cir . 1930), that we must make "as close an approximation as [we] can, bearing heavily if [we choose] upon the taxpayer whose inexactitude is of his own making." Even the Cohan rule, however, requires that we have some basis for estimating--where we don't, we can't just guess.
Rodriguez v. Commr. , T.C. Memo. 2009-22.
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