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sec. 6001. Under certain circumstances, where a taxpayer
establishes entitlement to a deduction but does not establish the
amount of the deduction, the Court is permitted to estimate the
amount allowable. See Cohan v. Commissioner, 39 F.2d 540 (2d
Cir. 1930). However, there must be sufficient evidence in the
record to permit the Court to conclude that a deductible expense
was incurred in at least the amount allowed. See Williams v.
United States, 245 F.2d 559, 560 (5th Cir. 1957). In estimating
the amount allowable, the Court bears heavily against the
taxpayer whose inexactitude is of his or her own making. See
Cohan v. Commissioner, supra at 544.
Section 274(d) overrides the Cohan doctrine in the case of
travel expenses, meals and lodging while away from home, and
"listed property". 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). Section 274(d) imposes stringent requirements to which
taxpayers must strictly adhere. Under section 274, a taxpayer
must substantiate the amount, time, place, and business purpose
of the expenditures and must provide adequate records or
sufficient evidence to corroborate his own statement. See sec.
1.274-5T(c)(1), Temporary Income Tax Regs., 50 Fed. Reg. 46016
(Nov. 6, 1985). Adequate records are defined as an account book,
diary, log, statement of expense, trip sheets, or similar
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