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As noted earlier, to qualify for deduction, an expense must
be both ordinary and necessary within the meaning of section
162(a). See Deputy v. duPont, 308 U.S. 488, 495 (1940). Whether
an amount claimed constitutes an ordinary and necessary business
expense is a question of fact to be determined from the evidence
presented with the burden being on the taxpayer. See Rule
142(a); Welch v. Helvering, 290 U.S. 111 (1933); Allen v.
Commissioner, T.C. Memo. 1988-166.
Additionally, a taxpayer is required to maintain records
sufficient to establish the amount of his or her income and
deductions. Sec. 6001. Under certain circumstances, where a
taxpayer establishes entitlement to a deduction but does not
establish the amount of the deduction, the Court is permitted to
estimate an allowable amount. See Cohan v. Commissioner, 39 F.2d
540 (2d Cir. 1930). However, there must be sufficient evidence
in the record to permit the Court to conclude that a deductible
expense was incurred for at least the amount allowed. See
Williams v. United States, 245 F.2d 559, 560 (5th Cir. 1957). In
estimating the amount allowable, the Court bears heavily against
the taxpayer whose inexactitude is of his or her own making. See
Cohan v. Commissioner, supra at 544.
However, in the case of travel expenses, specifically
including meals and lodging while away from home, as well as in
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