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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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