Joseph Baldwin Campbell - Page 20

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            meals and lodging while away from home, as well as in the case of                            
            entertainment, section 274(d) overrides the so-called Cohan                                  
            doctrine discussed earlier in this opinion.  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).  The Court is unable to use its                            
            discretion in allowing any of the travel expenses claimed by                                 
            petitioner.  Since petitioner did not substantiate his expenses                              
            under section 274(d), respondent is sustained on this issue.  The                            
            Court finds it unnecessary to consider the other arguments raised                            
            by respondent on this issue.                                                                 


                                                            Decision will be entered                    
                                                       for respondent.                                   






















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