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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;
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