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sufficient records to establish deduction amounts. Sec. 6001;
Meneguzzo v. Commissioner, 43 T.C. 824, 831-832 (1965).
Generally, except as provided by section 274(d), when evidence
shows that a taxpayer incurred a deductible expense, but the
exact amount cannot be determined, the Court may approximate the
amount. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.
1930). The Court, however, must have some basis upon which an
estimate may be made. Vanicek v. Commissioner, 85 T.C. 731, 742-
743 (1985).
A strict substantiation requirement exists under section
274(d)(4) for certain items listed under section 280F(d)(4) such
as passenger automobiles. Taxpayers must substantiate by
adequate records the following items in order to claim automobile
deductions: The amount of each automobile expenditure, the
automobile’s business and total usage, the date of the
automobile's use, and the automobile's business purpose. Sec.
274(d); secs. 1.274-5T(b)(6), 1.274-5T(c)(1), Temporary Income
Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985).
To substantiate a deduction by means of adequate records, a
taxpayer must maintain an account book, diary, log, statement of
expense, trip sheets, and/or other documentary evidence which, in
combination, are sufficient to establish each element of
expenditure or use. Sec. 1.274-5T(c)(2)(i), Temporary Income Tax
Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985). Section 274(d) is an
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