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taxpayer provides evidence sufficient to establish a rational
basis upon which the estimate can be made. See Vanicek v.
Commissioner, 85 T.C. 731, 743 (1985).
Section 274(d) supersedes the general rule of Cohan v.
Commissioner, supra, and we cannot estimate the taxpayer’s
expenses with respect to certain items. See Sanford v.
Commissioner, 50 T.C. 823, 827 (1968), affd. per curiam 412 F.2d
201 (2d Cir. 1969). Section 274(d) imposes strict substantiation
requirements for listed property (pursuant to sec. 280F(d)(4)).
See sec. 1.274-5T(a), Temporary Income Tax Regs., 50 Fed. Reg.
46014 (Nov. 6, 1985). In order to substantiate the amount of
expenses for listed property, a taxpayer must satisfy additional
factors, such as establishing the amount of business use for the
property, the amount of total use for such property, the amount
of each expenditure, and the investment or business purpose of
each use. See sec. 1.274-5T(b)(6), Temporary Income Tax Regs.,
50 Fed. Reg. 46016 (Nov. 6, 1985).
Expenses should be recorded at or near the time when the
expense is incurred. See sec. 1.274-5T(c)(1), Temporary Income
Tax Regs., 50 Fed. Reg. 46016 (Nov. 6, 1985). The record must
contain sufficient information as to each element of every
business use, but the level of detail will vary with each factual
variation. See sec. 1.274-5T(c)(2)(ii)(C)(1), Temporary Income
Tax Regs., 50 Fed. Reg. 46018 (Nov. 6, 1985). For example, if a
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