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statement of expense, trip sheet, and/or other documentary
evidence, which, in combination, are sufficient to establish each
element of expenditure or use. Sec. 1.274-5T(c)(2)(i), Temporary
Income Tax Regs., 50 Fed Reg. 46017 (Nov. 6 1985). Travel,
automobile, and entertainment expenses cannot be estimated under
Cohan. Sanford v. Commissioner, 50 T.C. 823, 827-828 (1968),
affd. per curiam 412 F.2d 201 (2d Cir. 1969).
Petitioner did not have any books or records. She did not
have a diary, a log, or trip sheets relating to her travel. At
trial, petitioner had little evidence to support many of her
claimed deductions. Many expenses appeared to be personal
expenses nondeductible under section 262. Petitioner provided
some substantiation for business expense deductions and
respondent conceded that she was entitled to most of those
deductions.
Petitioner was asked whether she could provide for MBS:
“Any kind of books or records that might show that [she] had any
reason to travel that year”. Petitioner’s answer was: “Not with
me, no.” Petitioner failed to comply with the strict
substantiation rules of section 274(a) and is not entitled to
deduct any travel, meals, and entertainment expenses. As to the
claimed $2,378 bad debt deduction for MBS, petitioner said: “I
mean, it’s not worth the headache to point out all the returned
checks, and matching it [sic] to my deposits” so she conceded
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Last modified: May 25, 2011