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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.
However, as to travel expenses, specifically including meals
and lodging while away from home, as well as in the case of
entertainment expenses and expenses with respect to listed
property, section 274(d) overrides the so-called 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). Section
274(d) imposes stringent substantiation requirements for
deductions related to travel, entertainment, gifts, and "listed
property (as defined in section 280F(d)(4))". Passenger
automobiles are listed property under section 280F(d)(4)(i).
Section 274(d) denies these deductions unless:
the taxpayer substantiates by adequate records or by
sufficient evidence corroborating the taxpayer's own
statement (A) the amount of such expense or other item,
(B) the time and place of the travel, entertainment,
amusement, recreation, or use of the facility or
property, or the date and description of the gift, (C)
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