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Heininger, 320 U.S. 467, 475 (1943). However, no deduction shall
be allowed for personal, living, or family expenses. Sec. 262.
Section 274(d) imposes stringent substantiation requirements
for the deduction of travel expenses (including meals and lodging
while away from home), entertainment expenses, gift expenses, and
expenses of certain listed property defined under section
280F(d)(4) such as an automobile. Taxpayers must substantiate by
adequate records certain items in order to claim deductions, such
as the amount and place of each separate expenditure, the
property's business and total usage, the date of the expenditure
or use, and the business purpose for an expenditure or use. Sec.
274(d); sec. 1.274-5T(b), Temporary Income Tax Regs., 50 Fed.
Reg. 46016 (Nov. 6, 1985).
To substantiate a deduction by means of adequate records, a
taxpayer must maintain an account book, diary, log, statement of
expense, trip sheets, and/or other documentary evidence which, in
combination, are sufficient to establish each element of
expenditure or use. Sec. 1.274-5T(c)(2)(i), Temporary Income Tax
Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).
If an expense item comes within the requirements of section
274(d), this Court cannot rely on Cohan v. Commissioner, supra,
to estimate the taxpayer's expenses with respect to that item.
Sanford v. Commissioner, 50 T.C. 823, 827 (1968), affd. per
curiam 412 F.2d 201 (2d Cir. 1969).
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