- 8 -
unconvincing. Petitioner, therefore, has failed to prove the
value of this contribution. Using our judgment, we find that the
fair market value of the donated property was $15. Thus,
petitioner is entitled to a deduction in this amount. See Cohan
v. Commissioner, supra; Zmuda v. Commissioner, supra.
Issue 3. Transportation Expenses
Petitioner claimed a deduction of $3,750 for unreimbursed
employee travel expenses for the miles that he drove between
hospitals on the days that he worked at more than one hospital.3
Section 274(d) imposes stringent substantiation requirements
for the deduction of travel expenses, entertainment expenses,
gift expenses, and expenses of certain listed property defined
under section 280F(d)(4) such as an automobile. See sec.
274(d)(1); sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed.
Reg. 46014 (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. See Sanford v. Commissioner, 50 T.C. 823,
827 (1968), affd. per curiam 412 F.2d 201 (2d Cir. 1969); sec.
1.274-5T(a)(4), Temporary Income Tax Regs., 50 Fed. Reg. 46014
(Nov. 6, 1985).
3Petitioner reported that he drove 12,500 business miles and
claimed the standard mileage deduction of 30 cents per mile.
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