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trial record provides sufficient evidence that the taxpayer has
incurred a deductible expense, but the taxpayer is unable to
adequately substantiate the amount of the deduction to which he
or she is otherwise entitled, the Court may estimate the amount
of such expense and allow the deduction to that extent. Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). However, in
order for the Court to estimate the amount of an expense, we must
have 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).
In the case of travel expenses, specifically including meals
and entertainment, as well as certain other expenses, section
274(d) overrides the so-called Cohan doctrine. Sanford v.
Commissioner, 50 T.C. 823, 827 (1968), affd. per curiam 412 F.2d
201 (2d Cir. 1969); sec. 1.274-5T(a), Temporary Income Tax Regs.,
50 Fed. Reg. 46014 (Nov. 6, 1985).
Under section 274(d), no deduction may be allowed for
expenses incurred for travel, or certain other expenses, on the
basis of any approximation or the unsupported testimony of the
taxpayer. Section 274(d) imposes strict substantiation
requirements to which taxpayers must strictly adhere. Thus,
section 274(d) specifically proscribes deductions for travel
expenses in the absence of adequate records, or of sufficient
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