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make regular rental payments. Petitioner offered as evidence of
his contributions three checks totaling $417 drawn on his newly
created checking account, payable to his mother. Petitioner was
physically present in Idaho when he delivered the checks to his
mother. These infrequent and nominal amounts are neither
substantial nor continuous. They are not strong indications that
petitioner was burdened by duplicate living expenses; indeed,
they indicate to the contrary. We accordingly conclude that
petitioner is not entitled to relief on the theory that his
employment in southern California was temporary. Kroll v.
Commissioner, 49 T.C. at 562.
b. Substantiation
For the sake of completeness, we summarily address whether
petitioner substantiated the expenses he claimed as travel
expense deductions. Even if petitioner had persuaded us that the
travel expenses he claimed as deductions were incurred while he
was “away from home”, the deductions would be disallowed because
petitioner has failed to meet the substantiation requirements of
section 274(d). Generally, when evidence shows that a taxpayer
incurred a deductible expense, but the exact amount cannot be
determined, the Court may estimate the amount allowable as a
deduction. Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.
1930). However, section 274(d) precludes the estimation of
travel expense deductions otherwise allowable under section 162.
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