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heavily against the taxpayer whose inexactitude in substantiating
the amounts of the expenses is of his own making. See Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). We may
estimate deductible expenses only where the taxpayer presents
evidence sufficient to provide some basis upon which estimates
may be made. See Vanicek v. Commissioner, 85 T.C. 731, 742-743
(1985). Section 274(d) supersedes this general rule allowing
estimates, however, and provides that--unless the taxpayer
substantiates certain elements--no deduction shall be allowed
with respect to: (1) Traveling expenses under section 162,
including meals and lodging while away from home; (2) any item
with respect to an activity of a type considered to be
entertainment, amusement, or recreation; or (3) the use of any
listed property, as defined in section 280F(d)(4) to include
passenger automobiles, computers and peripheral equipment, and
cellular telephones. For an expense described in any of the
above categories, the taxpayer must substantiate by adequate
records or sufficient evidence to corroborate the taxpayer’s own
testimony: (1) The amount of the expenditure or use based on the
appropriate measure; (2) the time and place of the expenditure or
use; (3) the business purpose of the expenditure or use; and (4)
in the case of entertainment, the business relationship to the
taxpayer of each person entertained. See sec. 274(d); sec.
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