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sufficient to provide some basis upon which an estimate may be
made. Vanicek v. Commissioner, 85 T.C. 731, 743 (1985).
Section 274(d) supersedes the Cohan doctrine. 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 traveling expenses under
section 212 or for expenses with respect to automobiles. To meet
the strict substantiation requirements, the taxpayer must
substantiate the amount, time, place, and business purpose of the
expenses. Sec. 274(d); sec. 1.274-5T, Temporary Income Tax
Regs., 50 Fed. Reg. 46006 (Nov. 6, 1985).
The first rental expenses at issue are the cleaning and
maintenance expenses for the Forestville property. To
substantiate these expenses, petitioner provided a summary
reconstructed from bridge toll receipts. The summary listed each
time period when petitioner was allegedly at the property after
crossing the bridge, along with an amount she allegedly paid
individuals--whoever happened to be in the neighborhood at the
time--to help her with cleaning and maintenance. She admits that
the time periods are estimates; nearly all of them are rounded to
the nearest hour. Although she testified that the amounts of the
expenses are based upon an hourly wage of $15 on each occasion,
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