9
Petitioner's estimated expense is based on an average of the
amounts of the four checks which were paid to Illinois Bell.
However, petitioner has not introduced any evidence to show that
these payments were each for a single month or that the charges
were representative of his typical usage. There is nothing in
the record enabling us to determine that petitioner incurred
telephone expenses in excess of $1,887. Respondent is sustained
on this issue.
Travel, Meals, and Entertainment Expenses
Section 162(a)(2) allows a deduction for travel expenses,
including meals and lodging. An exception to the Cohan rule is
section 274(d), which prohibits the estimation of expenses for
travel. Section 274(d) requires substantiation of travel
expenses either "by adequate records or by sufficient evidence
corroborating the taxpayer's own statement". Sec. 274(d). The
records must show the amount, date, place, and business purpose
of each travel expense. Id.; sec. 1.274-5T(b)(2), Temporary
Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
In order to be deductible as an expense incurred while "away
from home", a travel expense must be reasonable and necessary,
and incurred in pursuit of business. Commissioner v. Flowers,
326 U.S. 465, 470 (1946). For purposes of section 162(a)(2),
generally a taxpayer's home is his principal place of business.
Michaels v. Commissioner, 53 T.C. 269, 273 (1969). When a
taxpayer has two places of business or employment located a
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