-29- Respondent next asks us to find that petitioner has not adequately substantiated under section 274(d) his travel expenses. Section 274(d) overrides the Cohan doctrine with respect to expenses of travel away from home (including meals and lodging). See Sanford v. Commissioner, 50 T.C. 823, 827-828 (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). 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). Respondent conceded at trial that petitioner substantiated the amount, time, and place, but not the business purpose, of his travel expenses. In view of our holding that petitioner's inter- view expenses are nondeductible personal expenses, we find that his trips to Nevada served a dual purpose. This dual purpose warrants an allocation of travel expenses between business and nonbusiness use. While the evidence in this case does not permit an exact allocation, there is a basis for some allowance–if necessary, by drawing upon petiitoner’s own method of allocating his interview expenses. Petitioner characterized the money he paid to prostitutes as business related if he incorporated the material from the interviews in his book. According toPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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