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Taxpayers may deduct travel expenses incurred while away
from home in pursuit of a trade or business. See sec. 162(a)(2).
Traveling expenses are governed by the strict substantiation
requirements of section 274(d). Under section 274(d),
petitioners must substantiate by adequate records or by
sufficient evidence corroborating their own statement: (1) The
amount of the expense; (2) the time of travel; (3) the place of
travel; and (4) the business purpose of the expense. See sec.
274(d); sec. 1.274-5T(b)(2), (c)(1), Temporary Income Tax Regs.,
50 Fed. Reg. 46014 (Nov. 6, 1985). If petitioners fail to meet
the provisions of section 274(d), we cannot employ the principles
of Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930), to estimate
petitioners’ travel expenses. See Keating v. Commissioner, T.C.
Memo. 1995-101; sec. 1.274-5(a), Income Tax Regs.
To substantiate a deduction by means of adequate records, a
taxpayer must maintain an account book, diary, log, statement of
expense, trip sheets, and/or other documentary evidence which, in
combination, are sufficient to establish each element of
expenditure or use. See sec. 1.274-5T(c)(2)(i), Temporary Income
Tax Regs., 50 Fed. Reg. 46017 (Nov. 6, 1985).
Petitioners did not provide any records that would
substantiate when and where they traveled and the business
purpose of each trip. The receipts that petitioners submitted do
not satisfy the provisions of section 274(d). Petitioners have
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