Reza and Connie M. Rezazadeh - Page 20

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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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