- 30 - the taxpayer must meet the specific substantiation requirements of section 274, including the date, time, place, amount, and business purpose of the expense as well as the business relationship of those entertained by the taxpayer. Meridian Wood Products Co. v. United States, 725 F.2d 1183, 1188 (9th Cir. 1984). Section 274 precludes our making an estimate, under Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930), with respect to travel and entertainment expenses. See, e.g., Meridian Wood Products Co. v. United States, supra at 1188-1190. Even if section 274 were not applicable, there is insufficient evidence here to support an estimate of petitioners' claimed travel and entertainment expenses. There is also insufficient evidence to support an estimate under Cohan v. Commissioner, supra, for the remaining claimed deductions that fall outside of the substantiation requirements of section 274, such as business repair expenses. Petitioners have not indicated which expenditures have already been deducted on JKY's 1990 and 1991 returns. From the evidence before us, we cannot be certain that any of the claimed expenditures were actually for business purposes. Yoon did not testify as to the purpose of the expenditures. Also, from his testimony, it appears that Caufield, not Yoon, classified most of the expenditures on the schedules. We have been provided only with the amount of the alleged charges and the name of the place where the credit purchase was allegedly made. For the foregoingPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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