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the case of entertainment expenses and expenses with respect to
"listed property", section 274(d) overrides the so-called Cohan
doctrine. 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).
Section 274(d) imposes stringent substantiation requirements for
deductions related to travel, entertainment, gifts, and "listed
property (as defined in section 280F(d)(4))". Passenger
automobiles are listed property under section 280F(d)(4)(i).
Section 274(d) denies these deductions unless:
the taxpayer substantiates by adequate records or by
sufficient evidence corroborating the taxpayer's own
statement (A) the amount of such expense or other item,
(B) the time and place of the travel, entertainment,
amusement, recreation, or use of the facility or
property, or the date and description of the gift, (C)
the business purpose of the expense or other item, and
(D) the business relationship to the taxpayer of
persons entertained, using the facility or property, or
receiving the gift. * * *
Thus, under section 274(d), deductions for automobile expenses,
travel expenses, and meals and entertainment expenses may not be
estimated. Instead the taxpayer must provide adequate records or
corroborate testimony with other evidence.
Of the Schedule C expenses at issue, the following are
subject to the strict substantiation requirements of section
274(d):
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