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Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). However, in
order for the Court to estimate the amount of an expense, there
must be some basis upon which an estimate may be made. Vanicek
v. Commissioner, 85 T.C. 731, 743 (1985). Without such a basis,
any allowance would amount to unguided largesse. Williams v.
United States, 245 F.2d 559, 560 (5th Cir. 1957).
With respect to the medical expenses claimed by petitioner,
pursuant to Cohan v. Commissioner, supra, the Court is satisfied
that petitioner incurred $500 of the expenses claimed and,
therefore, is entitled to a deduction for that amount, subject to
the 5-percent limitation of section 213(a). With respect to
petitioner's unreimbursed employee business expenses for travel,
which specifically include vehicle expenses, section 274(d)
overrides the so-called Cohan rule. Sanford v. Commissioner, 50
T.C. 823, 827 (1968), affd. per curiam 412 F.2d 201 (2d Cir.
1969). Under section 274(d), no deduction may be allowed for
expenses incurred for travel on the basis of any approximation or
the unsupported testimony of the taxpayer. Section 274(d)
imposes stringent substantiation requirements to which a taxpayer
must strictly adhere. Thus, that section specifically proscribes
deductions for travel expenses in the absence of adequate records
or sufficient evidence corroborating the taxpayer's own
statement. Petitioner failed to present sufficient evidence to
meet the requirements of section 274(d) with respect to
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