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amount allowable, we bear heavily upon the taxpayer whose
inexactitude is of his or her own making. See Cohan v.
Commissioner, supra at 544.
For certain kinds of business expenses, such as travel,
meal, and entertainment expenses, and those expenses attributable
to “listed property”, section 274(d) overrides the rule of Cohan
v. Commissioner. 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). Under section 274(d), a taxpayer must satisfy strict
substantiation requirements before a deduction is allowable. See
sec. 274(d); sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.
If section 274(d) applies, we may not use the Cohan doctrine to
estimate a taxpayer’s expenses covered by that section.
The substantiation requirements of section 274(d) apply to
any listed property described in section 280F(d)(4). Listed
property includes passenger automobile and any other property
used as a means of transportation, see sec. 280F(d)(4)(A)(i) and
(ii), unless excepted by section 280F(d)(4)(C) or (d)(5)(B).
Petitioner’s pickup truck and car are listed property, and,
consequently, section 274(d) applies to the car and truck
expenses claimed by petitioner in 1992 and 1993.
To obtain a deduction for travel expenses under section 274,
a taxpayer must substantiate the amount of the expense, the time
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