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expenses is of his own making. See Cohan v. Commissioner, 39
F.2d 540, 543-544 (2d Cir. 1930). We cannot estimate deductible
expenses, however, unless the taxpayer presents evidence
sufficient to provide some rational basis upon which estimates
may be made. See Vanicek v. Commissioner, 85 T.C. 731, 743
(1985). Furthermore, section 274(d) provides that no deduction
is allowable under section 162 for any traveling expenses,
including meals and lodging while away from home, or for any
entertainment expenses, or with respect to any listed property,
defined in section 280F(d)(4) to include passenger automobiles,
unless the taxpayer complies with strict substantiation rules.
See sec. 274(d)(1), (2), (4). The taxpayer must substantiate the
amount, time, place, and business purpose of these expenses by
adequate records or by sufficient evidence corroborating his own
statement. See sec. 274(d); sec. 1.274-5T(b) and (c), Temporary
Income Tax Regs., 50 Fed. Reg. 46014, 46016 (Nov. 6, 1985).
These substantiation rules of section 274(d) supersede the Cohan
doctrine. 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),
Temporary Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).
Petitioners submitted various records and documents to
substantiate the claimed business expenses.2 We will separately
2 After the trial, respondent requested that his Exhibit
D in evidence be stricken from the record, and the Court informed
(continued...)
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