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Sanford v. Commissioner, 50 T.C. 823, 827 (1968), affd. per
curiam 412 F.2d 201 (2d Cir. 1969). Section 274(d) imposes
stringent substantiation requirements for certain deductions,
including travel, entertainment, and meal expenses. Jeffers v.
Commissioner, T.C. Memo. 1986-285; sec. 1.274-5T(a), Temporary
Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985). 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.
See Joseph v. Commissioner, supra. Section 274(d) also applies
to business use of certain property such as passenger
automobiles. Secs. 274(d)(4), 280F(d)(4)(A)(i).
In general, when a taxpayer's records have been lost or
destroyed through circumstances beyond his control, he is
entitled to substantiate the deductions by reconstructing his
expenditures through other credible evidence.
At trial, respondent conceded: "The record has shown today
that the records--the receipts and invoices that have been
presented to the Government have been reconstructed in such a way
that they are essentially the same as they would have been, had
they not been destroyed".
2. Advertising
Petitioner claimed a deduction for advertising expenses in
the amount of $830.16. To obtain clients, petitioner was
required to advertise her services. Petitioner created
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