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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 foregoing
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