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and Mrs. Thomason incurred expenses of $3,592.66 in connection
with the Florida condo activity during 1991. Those expenses are
allowed as Schedule E deductions.
With respect to petitioner's travel expenses in relation to
the Florida condo activity, which specifically include vehicle
expenses, travel, and meals, section 274(d) overrides the so-
called Cohan rule.11 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). Under section 274(d), no deduction may be allowed for
expenses incurred for travel on the basis of any approximation or
the unsupported testimony of the taxpayer. Section 274(d)
imposes stringent substantiation requirements to which each
taxpayer must strictly adhere. Thus, that section specifically
proscribes deductions for travel expenses in the absence of
adequate records or sufficient evidence corroborating the
taxpayer's own statement. Petitioners failed to present evidence
to meet the requirements of section 274(d) with respect to the
claimed deductions for vehicle expenses, travel, and meals
11
As a general rule, if the record provides sufficient
evidence that the taxpayer has incurred a deductible expense, but
the taxpayer is unable to substantiate adequately the amount of
the deduction to which he or she is otherwise entitled, the Court
may, in some situations, estimate the amount of such expense and
allow a deduction to that extent. Cohan v. Commissioner, 39 F.2d
540, 543-544 (2d Cir. 1930).
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