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amount of gross income, deductions, credits, or other matters
required to be shown on the tax return. If the books and records
are not adequate to establish the amounts of deductions or
credits, but we are persuaded that the taxpayer is entitled to
deduct more than the Commissioner allowed, then we are required
to make some estimate of how much more should be allowed,
“bearing heavily if * * * [we choose] upon the taxpayer whose
inexactitude is of his own making.” Cohan v. Commissioner, 39
F.2d 540, 543-544 (2d Cir. 1930). However, sections 274(d) and
280F(d)(4) provide that no deduction shall be allowed with
respect to passenger automobiles or any other property used as a
means of transportation unless the taxpayer substantiates certain
matters by adequate records or by sufficient records
corroborating the taxpayer’s own statement. There is no leeway
for Cohan type approximations under section 274(d). See Sanford
v. Commissioner, 50 T.C. 823, 827-828 (1968), affd. 412 F.2d 201
(2d Cir. 1969).
We are satisfied that petitioner paid about $15,220 for 9
months’ worth of American Express credit card charges. We may
fairly assume that petitioner paid additional amounts for the
other 3 months’ charges. But we do not have information that
persuades us that it is more likely than not that any of these
paid amounts satisfy the requirements of section 162(a) as
automobile expenses, and, as far as we can tell, the record is
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