- 20 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011