Gail Marie Harmon - Page 5




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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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