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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,
entertainment, and "listed property". 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. Under section 274(a), a
taxpayer must substantiate the amount, time, place, and business
purpose of the expenditures using adequate records or sufficient
evidence corroborating 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 records. See
sec. 1.274-5T(c)(2), Temporary Income Tax Regs., 50 Fed. Reg.
46017 (Nov. 6, 1985).
Petitioner contends that the repair expense claimed on his
Federal income tax return relates to repairs he made on a pickup
truck that was used exclusively for business. Passenger
automobiles are listed property under section 280F(d)(4)(A)(i).
With certain exceptions, any other property used as a means of
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