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Using the standard mileage rates, petitioners claimed deductions
for car and truck expenses on the Schedules C in the amounts of
$16,271 in 1995, $24,485.35 in 1996, and $20,361 in 1997.
Respondent disallowed these deductions in their entirety with the
exception of $304 allowed for 1997.
Taxpayers generally must keep records sufficient to
establish the amount of a claimed deduction. See sec. 6001; sec.
1.6001-1(a) and (e), Income Tax Regs. In the event that a
taxpayer establishes that a deductible expense has been paid but
is unable to substantiate the precise amount, we generally may
estimate the amount of the deductible expense bearing heavily
against the taxpayer whose inexactitude in substantiating the
amount of the expense is of his own making. See Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930). We cannot
estimate a deductible expense, however, unless the taxpayer
presents evidence sufficient to provide some basis upon which an
estimate may be made. See Vanicek v. Commissioner, 85 T.C. 731,
743 (1985).
Section 274(d) imposes stricter requirements and supersedes
the Cohan doctrine. See Sanford v. Commissioner, 50 T.C. 823,
827 (1968), affd. 412 F.2d 201 (2d Cir. 1969). Section 274(d)
provides that, unless the taxpayer complies with certain strict
substantiation rules, no deduction is allowable to the taxpayer
(1) for traveling expenses, (2) for entertainment expenses, (3)
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