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provide some basis upon which an estimate may be made. See
Vanicek v. Commissioner, 85 T.C. 731, 743 (1985).
Section 274(d) supersedes the Cohan doctrine. See Sanford
v. Commissioner, 50 T.C. 823, 827 (1968), affd. 412 F.2d 201 (2d
Cir. 1969). As relevant here, section 274(d) provides that,
unless the taxpayer complies with certain strict substantiation
rules, no deduction is allowable for meals and entertainment
expenses or with respect to listed property. Listed property
generally includes computers. Sec. 280F(d)(4). To meet the
strict substantiation requirements, the taxpayer must
substantiate the amount, time, place, and business purpose of the
expenses. See sec. 274(d); sec. 1.274-5T, Temporary Income Tax
Regs., 50 Fed. Reg. 46006 (Nov. 6, 1985).
We are not convinced that petitioner had a trade or business
within the meaning of section 162(a). Petitioner’s testimony
concerning the alleged business activity can be summarized as
follows. The business was started in May 1996 and lasted until
December 1996. Beverly Castillo, a personal friend of
petitioner’s, performed the housekeeping services, while
petitioner did marketing and business development. The business
started with six clients; Ms. Castillo already had been
performing housekeeping services for four of these clients before
petitioner became involved in the business. According to an
agreement, Ms. Castillo was to take all revenue from the first 10
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