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upon which estimates may be made. See Vanicek v. Commissioner,
85 T.C. 731, 743 (1985). Furthermore, section 274(d) provides
that, unless the taxpayer complies with strict substantiation
rules, no deduction is allowable for any traveling expenses under
section 162, for any entertainment expenses, or with respect to
any listed property. See sec. 274(d)(1), (2), (4). The taxpayer
must substantiate the amount, time, place, and business purpose
of these expenses by adequate records or by sufficient evidence
corroborating his own statement. See sec. 274(d). These
substantiation rules of section 274(d) supersede the Cohan
doctrine. See Sanford v. Commissioner, 50 T.C. 823, 827 (1968),
affd. 412 F.2d 201 (2d Cir. 1969).
Petitioner husband (Mr. Kuo) testified that in 1996 he was
the sole proprietor of a business named Kuos Technologies which
was involved in the development of a computer security system.
Assuming arguendo that Mr. Kuo in fact was engaged in a trade or
business during 1996, petitioners have failed to produce any
reliable evidence that he paid business expenses in excess of
those allowed as deductions by respondent. Furthermore, the
testimony by Mr. Kuo at trial indicated that many of the expenses
claimed are nondeductible personal expenses. Similarly,
petitioners failed to produce any reliable evidence showing the
proper amounts of additional rental expenses. We note that, even
if petitioners had provided such evidence, the propriety of the
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