- 4 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 Next
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