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United States, 245 F.2d 559, 560 (5th Cir. 1957). In estimating
the amount allowable, the Court bears heavily against the
taxpayer whose inexactitude is of his or her own making. Cohan
v. Commissioner, supra at 544.
The deduction for travel expenses away from home, including
meals and lodging, under section 162(a)(2), is conditioned on
such expenses being substantiated by "adequate records" or by
sufficient evidence corroborating the claimed expenses pursuant
to section 274(d). Sec. 1.274-5(a)(1), Income Tax Regs. To meet
the adequate records requirements of section 274(d), a taxpayer
"shall maintain an account book, diary, statement of expense or
similar record * * * and documentary evidence * * * which, in
combination, are sufficient to establish each element of an
expenditure". Sec. 1.274-5(c)(2)(i), Income Tax Regs. (emphasis
added). The elements to be proven with respect to each traveling
expense are the amount, time, place, and business purpose of the
travel. Sec. 1.274-5(b)(2), Income Tax Regs. The substantiation
requirements of section 274(d) are designed to encourage
taxpayers to maintain records, together with documentary evidence
substantiating each element of the expense sought to be deducted.
Sec. 1.274-5(c)(1), Income Tax Regs.
Respondent argued that petitioner's position with the EPC
was purely a volunteer position and, therefore, was not in
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