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business-related travel expenses that have been properly
substantiated.
Generally, with respect to the substantiation of expenses,
if the 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
the case of travel expenses, including meals and lodging while
away from home, 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); 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 on the basis of any approximation or
the unsupported testimony of the taxpayer. Section 274(d)
imposes stringent substantiation requirements to which taxpayers
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. At a minimum, the taxpayer must substantiate:
(1) The amount of such expense; (2) the time and place such
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