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As noted, to be entitled to a deduction under section
162(a)(2), petitioner must prove the expenses were: (1) Ordinary
or "normal, usual or customary", Deputy v. du Pont 308 U.S. 488,
495 (1940); (2) were necessary or "appropriate and helpful",
Welch v. Helvering, 290 U.S. 111, 113 (1933); and (3) bore a
reasonable and proximate relationship to the trade or business of
the taxpayer, Kinney v. Commissioner, 66 T.C. 122, 126 (1976);
Keating v. Commissioner, T.C. Memo. 1995-101; Hosbein v.
Commissioner, T.C. Memo. 1985-373. In addition, under section
274(d), petitioner must substantiate with adequate records or by
sufficient evidence corroborating his statement: (i) The amount
of such expense, (ii) the time, (iii) place, and (iv) the
business purpose of the expense. Sec. 1.274-5(b)(2), Income Tax
Regs. It is not enough to establish one of the elements, for
example, that a particular trip was business related; rather, all
of the elements must be established. Sec. 274(d). The
requirements are not subject to our discretion and, hence, we are
unable to estimate a taxpayer's expenses because section 274(d)
is intended to supersede Cohan v. Commissioner, 39 F.2d 540(2d
Cir. 1930); Keating v. Commissioner, supra; Jeffers v.
Commissioner, T.C. Memo. 1986-285; sec. 1.274-5(a)(3), Income Tax
Regs.
Petitioner testified that he traveled in connection with his
real estate business. Petitioner contends that he investigated
various golf courses for possible purchase. In that regard,
petitioner traveled several times a year. Petitioner was unable
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