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allowance of the entire amounts claimed for these expenses in his
tax returns. See Miller v. Commissioner, T.C. Memo. 1960-92,
affd. 295 F.2d 538 (8th Cir. 1961). Accordingly, we estimate
that the amounts allowed are the amounts claimed by petitioner
for these expenses on his tax returns for the years in issue.
See Huff v. Commissioner, T.C. Memo. 1994-451.
F. Car and Truck Expenses
In addition to satisfying the criteria for deductibility
under section 162, certain categories of expenses must also
satisfy the strict substantiation requirements of section 274(d)
in order for a deduction to be allowed. The expenses to which
section 274(d) applies include, among other things, automobile
expenses. Secs. 274(d)(4), 280F(d)(4)(a)(i) and (ii). We may
not use the Cohan doctrine to estimate expenses covered by
section 274(d). 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).
To substantiate a deduction attributable to listed property
(i.e., automobile expenses), a taxpayer must maintain adequate
records or present corroborative evidence to show the following:
(1) The amount of the expense; (2) the time and place of use of
the listed property; and (3) the business purpose of the use.
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