Eugene C. Joseph, Sr. - Page 6

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                 Under section 274(d), no deduction may be allowed for                               
            expenses incurred for travel, entertainment, or certain other                             
            expenses, on the basis of any approximation or the unsupported                            
            testimony of the taxpayer.  See, e.g., Joly v. Commissioner, T.C.                         
            Memo. 1995-413.  Section 274(d) imposes stringent substantiation                          
            requirements to which taxpayers must strictly adhere.  Thus,                              
            section 274(d) specifically proscribes deductions for travel or                           
            entertainment expenses in the absence of adequate records or of                           
            sufficient evidence corroborating the taxpayer's own statement.                           
                  Section 274(d)(4) also provides that no deduction is                                
            allowable with respect to listed property, as defined in section                          
            280F(d)(4), unless the deductions are substantiated in accordance                         
            with the strict substantiation requirements of section 274(d) and                         
            the regulations promulgated thereunder.  Included in the                                  
            definition of listed property in section 280F(d)(4) is any                                
            passenger automobile or any other property used as a means of                             
            transportation.  Sec. 280F(d)(4)(A)(i), (ii).                                             
                  To substantiate a deduction attributable to listed property,                        
            a taxpayer must maintain adequate records or present                                      
            corroborative evidence to show the following:  (1) The amount of                          
            the expense; (2) the time and place of use of the listed                                  
            property; and (3) the business purpose of the use.  Sec. 1.274-                           
            5T(b)(6), Temporary Income Tax Regs., 50 Fed. Reg. 46016 (Nov. 6,                         

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