- 11 - satisfy the strict substantiation requirements of section 274(d) in order for a deduction to be allowed. The expenses to which section 274(d) applies include, among other things, traveling expenses (which include expenses for meals and lodging while away from home), and entertainment expenses. See sec. 274(d)(1) and (2). We may not use the Cohan doctrine to estimate expenses covered by section 274(d). 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). 1. Traveling Expenses On her return, petitioner claimed a deduction for traveling expenses of $8,531 for tax year 1994. Of this amount, respondent concedes a deduction of $347 for expenses incurred by petitioner for parking. At trial, petitioner introduced copies of receipts and other documentation in support of her contention that she incurred traveling expenses of $9,003.69. Traveling expenses are subject to the substantiation requirements of section 274(d). See sec. 274(d)(1). No deduction is allowed for expenses incurred for travel away from the taxpayer’s home (including meals and lodging) unless the taxpayer substantiates, by adequate records or by sufficient evidence corroborating the taxpayer’s own statement, each of the following elements: (1) The amount of each separate expenditure;Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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