Joellen Miller Murata - Page 9

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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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