cohan rule estimates not permitted

frequently lose, this makes the use of estimates a very 3 0 obj CPAs should refer to AICPA Statement on Standards for Tax endobj h]fu|G[@)Si*h'DN \D ,>,Q}5 xxG:L1P$9]uE[V5F`dKouN3 x0]5E=$guq[X?MOE*_]H6]&v@n]b`wh|;m$a&XK}65fm#g Third, the rule only applies to help a court determine theamountof the taxpayers allowable deduction, not theexistenceof the underlying expense. sued McFerrin for return of the refund on the grounds that 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);}());} The Second Circuit found that it was clear that Cohan had incurred some expenses, even if he could not substantiate the exact amounts. 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. [See, e.g., IRC Section 170(f)(8)(A): No deduction shall be allowed under [Code section 170] subsection (a) for any contribution of $250 or more unless the taxpayer substantiates the contribution by a contemporaneous written acknowledgment of the contribution by the donee organization that meets the requirements of subparagraph (B).] The taxpayer must establish a verifiable contribution, as outlined in the regulations [IRC section 170(a) (1)]. How Much Should I Set Aside for 1099 Taxes? <> g1>co!i"L 1980) (the court held the patents cost to be $15,000 while the taxpayers testified that they cost $50,000). C.I.R., 37 T.C.M. var divs = document.querySelectorAll(".plc461033:not([id])"); Based on Cohans testimony, the BTA was apparently persuaded that 1) he had actually incurred expenses and 2) some, at least, of those expenses were related to his business activities. 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. 1976), affd, 615 F.2d 226 (5th Cir. 2005-157 and Stewart, T.C. difficult decision for preparers. Njg6P3C/F62eOnJaW+jg0A==:oi2UEd16nCGmeFNE2pQuoASb33Mm2p0yk6ktClVhYGeDJvBVDczbC/U05Kgcffbn9gZZv9r1VkY0ybDHqZ4slBPgtNg8yQSY1I9yUJDt4AUPHJ97IAK94NmPwbawD5Ax9xyc48Yr+WDWrdkZvisfwkUlLaFdj4z/bZxiEI6msdDkZX4RurXtNdDWKytNqDtKRvqNqviOJPna7fcJSWERPuRKs628n8iZD6ksaJnICRbn3LgBDqsFQ0jjhgLXdJy4SDvsstrwW9lgxnRoSExyULJ9UIlQCjJ2gwiVq5xKkMVvFBvNEv9NyCRmHipcv9a58hCRKuRU2b3LmpBUH5DBCiicCqnlJcMABRtWdjTd5IqqI8/Pa4CmMpEWwp/R0TGLzsH67Mk0R6u/h1dkGnrLdw==. These are in-person interviews in the IRS office. [35] See Partyka v. Commr of Internal Revenue, 8573-16S, 2017 WL 4973229, at *5 (T.C. 731,743(1985). However, relying on the Cohan rule is anything but certain. rules suggests that the Service should not be arbitrary in preparing many tax filings. 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. Mr. Cohan was perhaps the original Broadway pioneer. Nevertheless, and fortunately for taxpayers, courts have long recognized the potential injustice of completely disallowing an item (the existence of which they have been convinced) simply because the taxpayer lacks proof of the items exact amount. This article provides an overview of approximation in tax matters and notes where it has been limited by statute, regulations, and court decisions. He has been previously recognized as the Young CPA of the Year in the State of Texas (an award given to only one CPA in the state of Texas under 40). 1930)). . By using the site, you consent to the placement of these cookies. (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. [30] The core portion of the Cohan holding, however, remains, the possibility of substituting the Tax Courts estimation in place of a total disallowance for expenses not covered by Section 247(d). sections. taxpayer documents were destroyed by a wind and hail storm but var rnd = window.rnd || Math.floor(Math.random()*10e6); Second, it is not a license for taxpayers to simply guess or make up expenses (and therefore deductions), nor does it excuse sloppy recordkeeping. But records and documents are still occasionally lost, destroyed, purged, or otherwise difficult for the taxpayer to find or access. On appeal, the Second Circuit reversed the disallowance [Cohan, 39 F.2d 540 (1930)]. v. })(); var AdButler = AdButler || {}; AdButler.ads = AdButler.ads || []; Your use of the translations is subject to all use restrictions contained in your Electronic Products License Agreement and by using the translation functionality you agree to forgo any and all claims against ProQuest or its licensors for your use of the translation functionality and any output derived there from. George Cohan gave us "Yankee Doodle Dandy" and "Give My Regards to Broadway", and he gave us a tax deduction rule. But this obligation is more often honored in the breach. Longer documents can take a while to translate. [12] The Tax Court has also applied the Cohan Rule for patents even in cases where the records regarding the patents have been destroyed, though the final amounts entered by the Tax Court were far less than the taxpayers estimates. ; Contact Us Have a question, idea, or some feedback? The Fifth For instance, in The burden of proof falls on the taxpayer. Seems a bit onerous and even contradictory, but it is true. For these reasons, CPAs will benefit from a clearer understanding of theCohanrule, its requirements, its proper application in various circumstances, and its limitations. professional call as to when, if ever, estimates may be relied var plc289809 = window.plc289809 || 0; The Tax Court has applied the highest possible basis when a loss deduction was involved, [14] and the lowest possible basis when the amount of a gain was in dispute [15] when the basis of stock is estimated on the strength of submitted evidence. To be entitled to a deduction, a taxpayer must find a rule that allows the deduction and establish that he has satisfied all the rules requirements. However, ever since Congress enacted statutory amendments in 2006, a taxpayers failure to satisfy section 170s strict documentation requirements precludes any deduction [see, e.g.,Stewart T. Oatman, et ux., TC Memo 2017-17]. 1930)). addition, the Tax Court would not allow estimates when Under certain circumstances, a court may waive this requirement and allow the use of a deduction estimate. George M. Cohan, the famous entertainer, was disallowed a deduction for travel and business expenses because he was unable to substantiate any of the expenses. The Cohan Rule is now a law that allows taxpayers to deduct some of their business-related expenses even if the receipts have been lost or misplaced . Cl. 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. Please email support@keepertax.com if you have questions. 2005-212. These documents can be used to show the date payment was made and who received the payment. Mr. Freeman currently serves as the chairman of the Texas Society of CPAs (TXCPA). Cohan rule is a that has roots in the common law. Petitioner deducted his business expenses on his tax returns but because he failed to keep adequate . Earning a high income. about this column, contact Mr. Miller at johnmillercpa@cox.net. Gifts over $500,000 require an appraisal, a contemporaneous written acknowledgement and Form 8283 [IRC Section 170(f)(11)]. 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. Hide full disclaimer, Select results items first to use the cite, email, save, and export options. But it is not uncommon for busy individuals running a small business to forget to save their receipts, misplace them, or simply lose them. We want to hear from you. The ruling says that the expenses must be reasonable and credible, so you can't go saying that you spent $1,000 on a hammer or $500 on a burrito. 1930), if taxpayers can show that they paid a deductible expense but cannot substantiate the exact amount, the Tax Court may estimate an allowable amount. You should have a CPA, enrolled agent, or tax attorney to accompany you for the interview with these types of audits. The IRS regularly deals with missing receipts and will often allow you to prove those business expenses using other means. return preparers are frequently forced to use estimates 2005-212. [16]. Of course, the tax code provides taxpayer with numerous potential deductions; federal income tax deductions, however, are a matter of legislative grace [Indopco, Inc. v. Commr,503 U.S. 79, 84 (1992), noting the familiar rule that an income tax deduction is a matter of legislative grace and that the burden of clearly showing the right to the claimed deduction is on the taxpayer]. rule is based on a Second Circuit decision from 1930 in courts have refused to apply the rule. 1991), stating Cohanwould allow the tax court to estimate the losses;Portillo v. Commr, 932 F.2d 1128, 1134 (5th Cir. Reviewing your calendar. 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)]. 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. For example, the Cohan rule does not apply to items that are listed in, Section 274(d) of the Internal Revenue Code. Dont get lost in the fog of legislative changes, developing tax issues, and newly evolving tax planning strategies. Finally, even outside its original context (i.e., inadequately documented business deductions),Cohancontinues to be important because courts have relied on it to permit estimates in a variety of other circumstances. That is why we recommend you use a tax receipt organizer to properly track your records. C.I.R., 35 T.C.M. [22], The list above is not exhaustive. That sometimes leads us to generalize in our educational content. The Cohan Rule is a discretionary standard and can be used to support a reasonable estimate of compliance requirements.. It is a greataudit defense tool. It is important for preparers to understand that theCohanrule is of only limited utility: First, and perhaps most importantly, it is discretionary and not binding on a court. endobj For the 1999 tax year, McFerrins companies did not There is some support in The rule only applies to help a court determine theamountof the taxpayers allowable deduction, not theexistenceof the underlying expense. document.write('<'+'div id="placement_459481_'+plc459481+'">'); In McFerrin, No. Despite grossly inadequate records, Mr. Cohan was allowed a deduction based on close approximations provided to the court. A corollary is that the IRS is under no obligation to estimateor accept a taxpayer's estimateunder Cohan. indicates that some deduction should be allowed, the court can Read ourprivacy policyto learn more. expenses but could not provide adequate records In 823, 827-828 (1968), affd, 412 F.2d 201 (2d Cir. Treas. var abkw = window.abkw || ''; The rule allowing deduction of expenses is based on the principle that if the IRS asserts a deficiency but other evidence clearly indicates that some deduction should be allowed, the court can develop its own estimate. His rule is simple- you can approximate your business expenses and . 179D energy-efficient commercial buildings deduction, IRS provides guidance on perfecting S elections and QSub elections. Code because the Internal Revenue Service (IRS) does not follow the "Cohan rule." Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1.274-5T(b). As discussed below, the court inCohanpermitted estimates of deductions even though the taxpayer had no documentation of his claimed expenses. 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. Farouk contended that the Cohan rule (Cohan, 39 F.2d 540 (2d Cir. The Cohan Rule can and has been successfully applied to numerous deductions, including but not limited to: patents, patent applications, and copyrights; stock confiscated by a foreign government; and coin collections. You can then either accept the IRSs findings or file an appeal. 2002). estimates when the clients records do not strictly adhere to The Cohan Rule comes from a 1930 case involving the Broadway legend George M. Cohan. I know it was related to my business. Contacting suppliers and service providers for invoices and receipts. Charron v. United States, 200 F.3d 785 (Fed. When common sense (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). (CCH) 1232 (T.C. 1930) where the court held that the tax court may make a reasonable estimate of the allowable deduction, "bearing heavily if it chooses . My Research and Language Selection Sign into My Research Create My Research Account English; Help and support. [9] Coloman v. C. I. R., 540 F.2d 427, 432 (9th Cir. The CPA Journal However, on appeal, Judge Learned Hand reversed the IRS. creditable expenses. A recent Fifth Circuit decision 1968), affd, 440 F.2d 1 (6th Cir. any, added disclosures are required. Memo. 4 0 obj Without some documentation, the Cohan rule doesn't help you. in deciding whether to use estimates. Most importantly, preparers should bear in mind thatCohanwhere it is not altogether precluded by statutory documentation rulesrequires that taxpayers convince the IRS (or a court, should the matter be litigated) that they actually incurred an expense. Although a detailed discussion of section 274 is beyond the scope of this article, the important point relevant to this discussion is that section 274(d) imposes specific documentation standards that trump theCohanrule. Joseph Brophy is A taxpayer may not rely on theCohanrule where statutory or regulatory provisions specifically establish substantiation requirements. 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. using its authority. Taxpayers have relied on theCohanrule for decades, most often to justify estimates of allowable business deductions. This is not necessarily improper, in the absence of specific statutory documentation requirements, taxpayers and preparers are generally allowed to rely on estimates (e.g., Statement on Standards for Tax Services 4, Use of Estimates). 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. Deduction Estimate (When Can It Be Used)-Cohan Rule. It must be noted that the Cohan rule does not have a universal applicability. endstream endobj 496 0 obj <>stream You will have the option of providing the necessary documents and receipts, paying the amount the IRS says is due, or disputing the IRSs findings using an enrolled agent who is federally authorized to represent taxpayers. Luckily for Cohan, his case Keeper helps independent contractors and freelancers discover tax deductions and file taxes. The IRS will notify you of your audit by mailing you an audit letter by certified mail. 1990). These emails can also show that you made travel arrangements. Knowledge is power. However, gamblers typically do not keep complete records of their gambling wins and losses. endobj JFIF ` ` C George Cohan (Petitioner) was a theatrical manager, known for his contributions to Broadway and his over-the-top entertaining of both fans and critics. var plc461032 = window.plc461032 || 0; div.id = "placement_461033_"+plc461033; the regulations for taxpayers use of estimates. % travel, entertainment, business gifts, and expenses with <> Numerous circumstances call for approximation in tax matters, and almost all arise because the relevant documentary evidence never existed, is incomplete, or has been destroyed or lost. Yes, 1930 and we still use it today. As I understand the Cohanrule under the IRS Guidelines For Determining Noncompliance, taxpayers are allowed a deduction for an estimatedamount of expenses when it is clearthe taxpayer is entitled to a deduction but is unable to establish theexact amount of the deduction. Consequently, CPAs are often forced to prepare returns based on estimates. However, if you have no receipts, the IRS will not allow you to deduct the full amount of your expenses. ]/s]uUtH90WWy~gU 2{!evC|}\"Wg,xx2+12NOWxxAhAhAhAhAh 3P8C3Phg0@?@?@?W*z^eWU*zU2{^Ew~':rn)6)wsfooooo(3_32P3+v~_4~igrIs` 0 * What should the preparer do on original This functionality is provided solely for your convenience and is in no way intended to replace human translation. For example, taxpayers may need to determine their basis in property, value their property, or make allocations (e.g., between business and personal use of property). In these cases, the documentation itself is a requirement for the taxpayers entitlement to the item. Taxpayers are, of course, statutorily required to maintain adequate records to support the items reported on their returns (see IRC section 6001). <> Cohan rule is a former rule applicable in tax law. var plc461033 = window.plc461033 || 0; 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. (CCH) 1177 (T.C. The taxpayers threshold burden is to prove she actually incurred expenses, to provide the court with some basis for making an allocation or estimate. SLc`8|Y:oV=y"ry_v~%?F]|WWYj|buMAwN6Atlp~"buYw^ar]kq*%]\b%J+ZkouP;< Failure to do so leaves a court with no basis upon which to estimate a reasonable allowance, resulting in complete loss of the desired tax benefit: When a petitioner proves that some part of an expenditure was made for deductible purposes and when the record contains sufficient evidence for us to make a reasonable allocation, we will do so [Epp v. Commr, 78 TC 801, 807 (1982)]. The Fifth Circuit has While not impossible The IRS argued that even if responsibility to clients to consider estimates while Authority for Estimates - Cohan Rule When the TP establishes that the TP paid or incurred deductible expenses but does not establish the amount of the deduction to which TP is entitled, TP may be entitled to estimate the amount allowable. Cir. One of the first cases to allow estimates in federal tax matters was Cohan v. Comm'r [39 F.2d 540 (2d Cir. the taxpayer failed to make efforts to reconstruct the records The rule was outlined in the courts decision in Cohan v. Commissioner, which involved undocumented business deductions claimed by the famous Broadway showman George M. Cohan. stream engineer. The case demonstrates the courts reluctance to use testimony as an exclusive corroboration to substantiate an expense under IRC section 274. 2022 The New York State Society of CPAs. Oops! 6/9/09), the taxpayer owned several S 1.2745T(b); see also Sham v. Commissioner, T.C. 1930)) should permit the court to estimate the appropriate allocation of wages between qualified and nonqualified services. [34] 26 C.F.R. <> var plc459481 = window.plc459481 || 0; [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. 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. Fairly stringent statutory documentation requirements are also imposed on charitable contributions. The judge wrote that absolute certainty in such matters is usually impossible and is not necessary, the Board should make as close an approximation as it can. In general, the Tax Court has interpreted this ruling to mean that in certain situations best estimates are acceptable in order to approximate expenses. x]k0{J*K>Q 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? Cohan rule is a that has roots in the common law. hbbd``b`@HpA\,q b,Ay XDlq %$ O@BHH 1 2\h!crF% e 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. Association of International Certified Professional Accountants. [29] See Gill v. United States, 296-81T, 1997 WL 820963, at *43 (Fed. The Cohan rule allows courts to estimate certain expenses not prop-erly substantiated. possible, practitioners must use their professional judgment 1981-176]. strict compliance with documentation standards may not be 1.41-4 (CCH) 1392 (T.C. 1996-308;Bernardeau v. Commr, T.C. Moreover, there are still numerous cash transactions in the U.S. economy; in these circumstances, theCohanrule continues to be important. ), the court determined that the basis in the stock was at least equal to its par value. conclusion in Stewart, T.C. C.I.R., 301 F.3d 339, 358 (5th Cir. 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'; 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. Mr. Freeman was named the Leading Tax Controversy Litigation Attorney of the Year for the State of Texas for 2019 and 2020 by AI. ",#(7),01444'9=82. So if you have received notice from the IRS that you are the subject of a tax audit and cannot find all relevant receipts, you are not alone. strictly comply with the Sec. Related examination. Id. 1930), Armando Sandoval Lua v. CommissionerTC Memo 2011-19. We know every form you need and every deduction you can take to pay less this year. The receiving organization must supply a receipt or written communication from the donee organization showing its name, plus the date and amount of the contribution [IRC section 170(f)(17)]. Tax Court concluded that the taxpayer could not use general Failure to report income to the IRS that is included on Form 1099s filed by businesses that have made payments to you. Your submission has been received! A taxpayer must adequately establish an evident right to a deduction[7] as well as provide some basis for such an estimate. In Cohan v. Commissioner of Internal Revenue, 39 F.2d 540 (2d Cir. [34] In tax law, however, the concept of substantiation means more than to simply keep track, it can also mean documenting or proving the fair market value of any item or deduction in question.[35]. 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. Interestingly, these expenses were nearly all travel and entertainment expenses, which today would be either limited or wholly disallowed by IRC section 274, without regard to documentation. endobj Careful in your research -Cohan was previously allowed for charitable contributions. All rights reserved. 165(g)(3), Recent changes to the Sec. <>/Metadata 912 0 R/ViewerPreferences 913 0 R>> [21] Id. Indeed, it might be a rare taxpayer who, like the taxpayer inCohan, iswhollyunable to document the existence and the amount of a disputed item. As discussed below, the court in Cohan permitted estimates of deductions even though the taxpayer had no documentation of his claimed expenses. On audit, Cohan was unable to substantiate these expenses with documentary evidence, and the IRS disallowed the deductions in full. He enjoys hiking, traveling, and studying tax law. endobj var abkw = window.abkw || ''; Memo. But this obligation is more often honored in the breach. The Fifth Circuit said the var absrc = 'https://servedbyadbutler.com/adserve/;ID=165519;size=300x250;setID=282686;type=js;sw='+screen.width+';sh='+screen.height+';spr='+window.devicePixelRatio+';kw='+abkw+';pid='+pid282686+';place='+(plc282686++)+';rnd='+rnd+';click=CLICK_MACRO_PLACEHOLDER'; The rule was outlined in the court's decision in Cohan v. respect to listed property. Enter Cohan vs. Commissioner, 39 F. 2d 540 (2d Cir. You can save searches, save documents, create alerts and more. Noncash gifts over $500 require additional details on Form 8283. Have a question, idea, or some feedback? John K. Cook, JD, LLM is an associate professor of accountancy at Wright State University, Dayton, Ohio. [13] See Reese at 226 (5th Cir. allowing deduction of expenses is based on the principle that Rejecting the IRSs objections, the court stated that absolute certainty in such matters is usually impossible and is not necessary; the Board should make as close an approximation as it can, bearing heavily if it chooses upon the taxpayer whose inexactitude is of his own making (Cohan, 39 F.2d, at 544). if the IRS asserts a deficiency but other evidence clearly 1971). 2005-15, the In Cohan, the court made an exception to the rule requiring taxpayers to substantiate their business expenses. mercy of the Service, but a reasonable interpretation of the How to Survive Getting an IRS Audit Notice (With Free Response Template!). dictates that the taxpayer had some expense (or credit) but What benefit does the Cohan rule provide for taxpayers with incomplete business records the business or taxpayer will be allowed to estimate and deduct certain types of business expenses only if? 274(d), which requires substantiation for Patents, patent applications, and copyrights. endstream endobj startxref The Service maintains that 26 USCA 274(d) supersedes the Cohan rule by disallowing certain categories of expenses (including most entertainment, travel, and gift expenses) and supersedes the Cohan rule. 4 0 obj Where a taxpayer was unable to prove that he had any basis in the coins sold, the court (affirmed by the Sixth Circuit) allowed a basis of 75% of the selling price due to the IRS treatment of the gains as a short-term capital gain. the addition of Sec. In other words, the appellate court held that the BTA, having been convinced by the taxpayers testimony of theexistenceof deductible expenses, ought to have estimated the properamountthereof.

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