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280F(d)(4),3 however, section 274(d) requires taxpayers to
substantiate:
by adequate records or by sufficient evidence
corroborating the taxpayer's own statement (A) the
amount of such expense or other item, (B) the time and
place of the travel, entertainment, amusement,
recreation, or use of the facility or property, or the
date and description of the gift, (C) the business
purpose of the expense or other item * * *
Section 274(d) is an exception to the Cohan rule and
prohibits the estimation of such expenses. Sanford v.
Commissioner, 50 T.C. 823, 827-828 (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).
For deductions involving the use of listed property, the
Commissioner is authorized to establish mileage allowances that
are deemed to satisfy the substantiation requirements as to
amount. Sec. 1.274(d)-1, Income Tax Regs. The specific mileage
allowance for 1993 was 28 cents a mile. Rev. Proc. 92-104, 1992-
2 C.B. 583, 584. The specific mileage allowance for 1994 was 29
cents a mile. Rev. Proc. 93-51, 1993-2 C.B. 593, 594. Time and
place of the mileage expense can be substantiated by a
"contemporaneous log of business mileage or by otherwise
establishing a taxpayer's business travel." Smith v.
Commissioner, 80 T.C. 1165, 1173 (1983). Business purpose may be
3 Sec. 280F(d)(4) defines listed property to include passenger
automobiles.
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